Draft notice
The text on this page is a working draft. Counsel-reviewed copy will replace this before any hard launch, regulated transaction, or jurisdiction-specific compliance commitment. Use this version as a structural reference only.
1. Who we are
Circularity Global ("we", "us") is the data controller for personal data collected via the Platform. Contact us at privacy@circularity.global to exercise your rights.
2. Data we collect
- Account data: name, email, organisation, country, role.
- KYC data (investors): identity documents, source of funds attestations, address verification.
- Activity data: engine runs, calculator inputs, marketplace listings, EOIs, Academy progress.
- Technical data: device, browser, language, anonymised IP. Used for security and analytics.
3. Why we use it
- To operate, secure and improve the Platform.
- To process KYC, marketplace matching and investor onboarding.
- To send transactional emails and (with consent) product updates.
- To meet legal, regulatory and tax obligations.
4. Legal bases
Contract, legitimate interest, consent, and legal obligation depending on activity.
5. Sharing
We share data with service providers (cloud, email, KYC vendor, payment processor) under contract. We never sell personal data.
6. Retention
We keep account and activity data while your account is active and for a reasonable period after, in line with regulatory requirements. KYC records are kept per AML statutes (typically 5–7 years).
7. Your rights
Access, rectification, deletion, portability, restriction, objection and (where applicable) lodging a complaint with a supervisory authority.
8. International transfers
Where data is transferred outside your home jurisdiction, we use Standard Contractual Clauses or equivalent safeguards.
9. Security
TLS in transit, encryption at rest, role-based access, audit logging. No system is perfectly secure; we encourage strong, unique passwords and 2FA when available.