Privacy Policy

1. Who we are

Cirqle Ltd is a company registered in England and Wales [company number — to be added], registered office [registered address — to be added]. We are registered with the Information Commissioner's Office (ICO) under registration [ICO registration number — to be added].

For any privacy question or to exercise your rights, contact privacy@cirqle.co.uk.

2. What data we collect

• Account data: your first and last name, email address, password (stored only as a secure bcrypt hash — never in plain text), your Instagram handle, and the date you signed up.
• Cashback claims: photos of receipts you upload (stored privately), the deal you claimed against, the Instagram post linked to the claim (if any — a repeat visit can be logged without one), and the cashback amount and its status (pending, confirmed, paid, or rejected).
• What your receipt says: we read each receipt automatically to check the claim. From that reading we keep the shop's name, the total, the currency, the purchase date and the order or transaction number. We do this to confirm the purchase is genuine and not a duplicate, and to tell the brand what their deals earned. The automatic reading is done by AI, which receives the receipt image itself — see section 5. This is not used to train any AI model. We also keep the ability to read a receipt using Amazon Textract inside our own AWS account, used when a claim needs a manual re-check.
• Instagram post data: where you provide an Instagram handle and refresh your feed, we collect public posts that tag our brand account — see section 4.
• Technical data: our website is hosted on GitHub Pages and our API on Amazon Web Services (AWS). As part of normal operation and security, those providers process standard request data such as your IP address, the time of the request, and your browser type. We do not run our own advertising or analytics tracking.
• Brand / partnership data: if you apply to partner with us as a brand, we collect the business and contact details you submit in that form.

We do not collect payment card numbers, and we do not buy personal data or track you across other websites.

3. How & why we use it

Under UK GDPR we must have a "lawful basis" for each use of your data:

We only send marketing if you have opted in, and every marketing email has an unsubscribe link.

4. Instagram data

Cirqle's cashback model asks you to post about a purchase on Instagram and tag our account. (Once you have claimed a deal, some brands also let you log a repeat visit from just the receipt, with no post — that route involves no Instagram data at all.) To check that a qualifying post exists, we retrieve public Instagram posts that tag our brand account and match them to the Instagram handle on your account. For those posts we may process the post's URL, caption, timestamp, the posting account's username and display name, and public like/comment counts.

We use this only to verify your cashback claim. You control which handle is on your account, and you can remove or change it at any time. This retrieval is performed for us by a third-party provider (see section 5). We are reviewing this mechanism and may change how post verification works in future; we will update this policy if we do.

5. Who we share it with

We do not sell your personal data. We share it only with service providers ("processors") who act on our instructions, and where the law requires:

• Amazon Web Services (AWS) — hosting, database, private receipt storage, and email delivery. Your data is stored in AWS's UK (London) region. AWS's Amazon Textract service is also used to read a receipt when a claim needs a manual re-check.
• An AI provider — reads your receipt image automatically to check a claim, as described in section 2. Does not train its models on this data.
• Apify — retrieves the public Instagram post data described in section 4.
• GitHub (GitHub Pages) — serves our website.
• Google Fonts — serves the fonts our pages use; this may involve your browser's IP address being seen by Google.
• Brand partners: a brand you have claimed cashback from can see your activity with that brand, in their partner dashboard. This is set out in full below.
• Other Cirqle members — only if you choose to join the referral leaderboard, which is off unless you turn it on. This is set out in full below.
• A payment provider — when cashback withdrawals go live, to pay out your balance (not active yet).
• Authorities or advisers — where we are legally required to disclose, or to protect our rights.

What a brand can see about you

When you claim cashback from a brand, that brand pays for it, and they get a dashboard showing how their deals performed. Because a claim is something you did with them, your activity appears in it. We think you should know exactly what that means, so here it is in full.

A brand you have claimed from can see, about you:

• Your Instagram handle, and the public post you tagged them in — its image, caption, and public like and comment counts.
• How many times you have claimed with them, and the dates of your first and most recent claim.
• The total printed on the receipts you uploaded to them, and the cashback they paid you.
• Whether someone referred you to them and that person's Instagram handle — and, if you referred anyone to that same brand, their handles too.

A brand can never see:

• Your name, email address, phone number, postal address, date of birth, or bank and payment details.
• Your receipt images, or the individual items on them. Only the total is shared.
• Anything at all about your activity with any other brand. Each brand sees only their own shop. A brand cannot learn that you also shop with a competitor, how much you spend elsewhere, or how many brands you use Cirqle with.
• Your Cirqle balance, withdrawals, or account history.

Where a brand's dashboard shows grouped statistics — for example the share of their customers who returned in a given month — we withhold any group containing fewer than five people, so that a figure can never be traced back to one person.

We share this because it is necessary for the contract between us: the brand funds your cashback, and cannot reasonably be asked to pay for purchases they are shown nothing about. It is also our legitimate interest in running a marketplace that brands will fund. Brands act as separate data controllers for what they see, and our partner agreement forbids them from using it to identify you beyond your handle, from combining it with data from elsewhere to do so, or from contacting you outside Cirqle.

If you would rather a brand did not see this, do not claim cashback from them. You can also ask us to delete your account at any time (section 8), which removes your claims from every brand dashboard.

What other members can see about you

We run a referral leaderboard: a table of members ranked by how many people they have referred to Cirqle. You are not on it unless you choose to be. It is off for every account by default, and joining is a decision you make on the leaderboard page.

If you join, other signed-in members can see:

• A name for you — either one you type in yourself, or, if you don't, the Instagram handle on your account.
• How many people you referred during the current three-month season, and your position in the table.

Other members can never see:

• Your real name, email address, or any contact details — unless you type your own name in as your display name.
• Anything you bought, any brand you shop with, any receipt, or any amount of money: not your cashback, not your balance, not your withdrawals.
• Who referred you, or who you referred.

You can leave the leaderboard at any time, which removes you from the season currently running. A season that has already closed keeps the standings it had, because the prizes for that season were decided on them. Deleting your account (section 8) removes you from every leaderboard, past and present.

We rely on your consent for this, which is why it is off by default and why turning it off again is always available.

If you win a prize

Members who finish in the top ten of a season win a cash prize. To pay it we will contact you and ask for the bank details we need to make the transfer. We do not store bank details on your account. We use them to make the one payment, keep whatever record of the payment we are required to keep for tax and accounting, and delete the rest.

6. International transfers

Your account and cashback data is stored in the UK (AWS London region). Some of our providers (for example our AI provider, Apify, Google, and GitHub) may process limited data outside the UK. Where they do, we rely on appropriate safeguards — such as UK "adequacy" decisions or the International Data Transfer Agreement — to keep your data protected to UK standards.

7. How long we keep it

• Account data — while your account is open, and for a short period after closure to handle any final queries.
• Cashback and financial records — up to 6 years, to meet UK tax and accounting requirements.
• Sign-in codes and password-reset links — minutes only (they expire quickly by design).
• Cached Instagram posts — until you refresh them or close your account.

You can ask us to delete your account and associated data at any time (subject to records we must keep by law).

8. Your rights

Under UK GDPR you have the right to:

• Access the personal data we hold about you.
• Have inaccurate data corrected.
• Have your data erased ("right to be forgotten").
• Restrict or object to certain uses of your data.
• Receive a portable copy of the data you gave us.
• Withdraw consent (for anything based on consent) at any time.

To exercise any of these, email privacy@cirqle.co.uk. We aim to respond within one month. If you're unhappy with how we handle your data, you can complain to the ICO at ico.org.uk.

9. Security

We protect your data with measures including: passwords stored only as bcrypt hashes; receipt images held in private storage and viewable only through short-lived, signed links; encrypted connections (HTTPS/TLS); and hosting on AWS's UK infrastructure. No system is ever completely secure, so please use a strong, unique password for your Cirqle account and keep it private.

10. Cookies & storage

We do not use advertising or tracking cookies. To keep you signed in and remember a few preferences, we use your browser's local storage. Full details are in our Cookie Policy.

11. Changes & contact

We may update this policy from time to time. If we make a material change, we'll post a notice on the site and, where appropriate, email you. Questions or requests: privacy@cirqle.co.uk, or via our contact page.