PhotoCircle Privacy Policy

Last Updated: October 5, 2026

This Privacy Policy explains how we collect, store, share, maintain, and otherwise use the personal information that we gather on the subdomains and websites on photocircleapp.com (the “Site”), through the use of our native mobile Android and iOS applications (the “App”), and any other services offered as part of the PhotoCircle platform (collectively with the Site and App, the “Services”). The Site and App are operated by PhotoCircle, Inc. (“PhotoCircle,” “we,” “us,” and/or “our” as used in this Privacy Policy).

This Privacy Policy does not apply to the way we process End User information on behalf of our Customers, except for (a) our data retention and deletion practices described in Section 13, which apply to all information we process regardless of whether we are acting as a controller or a processor, (b) the age confirmation practices described in Section 14, which apply to every User because they meet our own legal obligations, and (c) our cooperation with law enforcement and the disclosures described in Section 11. Where a separate written agreement with a Customer expressly provides otherwise, that agreement governs instead, except that the age confirmation practices in Section 14 and the cooperation and disclosures in Section 11 cannot be set aside by agreement. In processing End User information on behalf of our Customers, we safeguard that information in accordance with our agreements with our Customers.

Table of Contents

1. Whose Personal Information We Collect

2. How We Collect Information from You

3. How We Use Your Information

4. How We Share Your Information

5. Do Not Track

6. Cookies

7. Family Educational Rights & Privacy Act (FERPA)

8. Privacy Rights & Additional Disclosures for EEA, UK & Swiss Individuals

9. Privacy Rights & Additional Disclosures for Certain US State Residents

10. Your Privacy Choices (Do Not Sell or Share)

11. Disclosures Related to Child Sexual Abuse Material (CSAM) and Legal Obligations

12. How We Secure Your Information

13. How We Retain Information

14. Children’s Privacy

15. Change of Control

16. Account Deletion

17. Policy Updates

18. Contact Us

1. Whose Personal Information We Collect

We obtain information from various entities and individuals. These entities and individuals are defined below by what they are referred to in this Privacy Policy and when their information is collected. Definitions may overlap and are not exclusive categories.

The use of “you” and “your” throughout this Privacy Policy will, depending on the context, refer to a Customer, Consumer End User, or Website Visitor.

All capitalized terms used in this Privacy Policy shall have the meaning given to them in the Terms of Use unless otherwise defined or stated herein.

2. How We Collect Information from You

Information You Give Us. You may give us information by signing up for an account, entering information through forms or surveys, inputting information while using our services, or by contacting us by phone or email for information or customer service.

The categories of information include:

Information About End Users We Collect for PhotoCircle Customers. If your company or school or other institution engaged our Services, we may collect information from you on their behalf as a service provider. This information may be passively recorded from interactions on your browser or device, or it may be through integrations with the Customer’s software. This information may include:

Information the App Receives from Advertising Service Providers. When you use the free, ad-supported version of the App, the App may obtain an online identification code (such as the RampID described in Section 3) from our identity resolution provider by sending it a hashed form of your email address. The App holds that code on your device as one of your Ad Identifiers; it is not sent to or stored on our servers.

If a Customer has engaged us, we may collect information from you on their behalf as a service provider. However, because we process and safeguard information on the Customer’s behalf, you should contact the Customer directly for information regarding how they use and share personal information gathered from using our Services.

When you are invited to become a Workspace User, your Workspace User account and activity therein is associated with the Workspace. If you use the same email to accept a Workspace User invitation that you used with an existing PhotoCircle account, information from the existing account will be transferred to the Workspace User account.

When You Visit Our Website. Like many websites, we collect information that your browser sends whenever you visit our Website. This includes log data, such as IP address, browser type, browser version, pages of our Website that you visit, the time and date of your visit, the time spent on those pages and other statistics, and how you reached our Website. This may be collected via several technologies, including cookies. You can control cookies in your browser to enable or disable them. Learn more in our Cookie Policy.

Metadata in Uploaded Media. Photos and videos often contain embedded technical metadata, such as EXIF data. When you upload Media to the Services, we preserve two parts of that metadata with the Media: the date and time the media was captured, and its precise geographic location (latitude, longitude, and altitude) if location services were enabled on the capturing device. Other metadata, such as camera and device information, is not kept. The preserved date and location stay with the Media and are included in copies of the Media that you or other Users of a Circle download. We do not currently display location information in the App, though we may offer location-related features in the future, and we do not use it for advertising or profiling. You can prevent us from receiving location information by disabling location tagging in your device’s camera settings before capturing media, or by removing location metadata from files before uploading them. Where we have identified a User as under the age of 18, we do not preserve location metadata from Media they upload; it is removed before the Media is stored. See Section 14.

3. How We Use Your Information

We use your personal information for the following purposes:

Marketing. We may use your personal information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You have the right to object to the use of your personal information for direct marketing purposes at any time. You can exercise this right by following the unsubscribe instructions in any marketing email, adjusting your notification preferences in the app, or contacting us at privacy@photocircleapp.com. You will still continue to receive service-related messages concerning products and services you have purchased (unless we have indicated otherwise). We do not send marketing communications to Users we have identified as under the age of 18.

Showing Quality Advertisements for Free Users. When you use the free version of the App, we may show you advertisements within the App based on your interests. This involves using identifiers assigned by Apple on iOS and Google on Android, respectively, to entice advertisers to bid to occupy ad space on the PhotoCircle App when they want to offer a product or service that might suit a user.

Identity Resolution & Ad Partner Identifiers. To make the ads we show more relevant and to help advertisers measure their campaigns, we work with an identity resolution provider — currently LiveRamp, Inc. Where your device settings allow personalized ads, the App may send LiveRamp a hashed (one-way) form of your email address, and LiveRamp returns an online identification code (a “RampID”). The App holds that RampID on your device and includes it in the ad requests it makes to advertising companies to enable interest-based and cross-channel advertising. Those requests are made directly from your device, so the advertising company receiving them also sees your device’s IP address, as described in Section 4.

The RampID is a code: it does not reveal your email address or any other directly identifying information to the advertising companies that receive it.

Fraud and Invalid Traffic Prevention. We and our advertising partners also use your IP address, together with device and ad-delivery signals, to detect and filter invalid traffic — automated bots, data-center traffic, and other activity that is not a real person viewing a real advertisement. This protects advertisers from paying for fraudulent impressions and protects our ad space from being abused.

You can opt out of the use of your information by LiveRamp at liveramp.com/opt_out/. You can also opt out of all selling and sharing of your information for advertising purposes through PhotoCircle directly — see Section 10, “Your Privacy Choices.”

You can control personalized advertising on both Apple and Google platforms.

If you are using the iOS App and do not have an ad-free subscription, as of the date of this Policy, we use Apple’s IDFA, and you may be prompted to Allow tracking across apps and can tap “Ask App not to track” to opt out of seeing personalized advertisements on PhotoCircle. If you allow tracking, we will show ads on PhotoCircle that are personalized to your interests. If you use an earlier version of iOS, you can disable tracking by going to your phone’s “Settings” menu. If you do not allow tracking, we will not use IDFA to show you personalized ads on PhotoCircle. You will instead still see general ads on PhotoCircle, but they will not be personalized.

If you are using Android and do not have an ad-free subscription, we use Google’s Advertising ID (GAID). As of the date of this Policy, you can opt out of personalized ads on PhotoCircle by heading to Settings on your Android device. Once you do so, we will stop showing you personalized ad recommendations on PhotoCircle. However, you will still see ads on PhotoCircle as a free user, but they will not be personalized.

If we have identified you as under the age of 18, we do not ask for tracking permission and we show you only non-personalized ads. See Section 14.

We refer to the GAID, the IDFA, and the RampID described above collectively as “Ad Identifiers” in this Policy.

Ad Reporting. When you report an advertisement, we collect limited information to help us review and address the issue. This includes details about your device and app version, the ad you reported, and a screenshot of the ad itself.

We link this report to your account internally to prevent abuse and improve ad quality. The screenshot only includes the ad content—not other parts of your screen or profile.

To help us investigate and prevent similar ad issues, we may share the ad screenshot (without any user identifiers) with the advertising partner responsible for serving that ad. These partners use the screenshot solely for compliance review, fraud detection, and quality assurance.

We do not share any information that identifies you or your device with advertisers, and we delete or anonymize the screenshot once the review process is complete.

Automated Image Scanning. We may use automated content scanning technologies to identify and remove child sexual abuse material (CSAM), in accordance with applicable U.S. law. These technologies, such as Microsoft PhotoDNA, work by creating a cryptographic hash of an uploaded image and comparing it to a database of known CSAM hashes. No human sees your images during this automated scanning process unless flagged for review due to a policy violation.

For users in the European Economic Area (EEA) or Switzerland, these tools are only applied:

This process supports our efforts to prevent illegal activity on the platform and ensure user safety. You can learn more about our use of PhotoDNA and our commitments to privacy by contacting us at privacy@photocircleapp.com.

4. How We Share Your Information

We share your personal information with third parties in accordance with this Privacy Policy.

Ad Identifiers and Related Information. For free Users, the App includes the applicable Ad Identifiers in the ad requests it makes to advertising networks and mediators, to allow ad publishers to submit bids to fill our ad spaces and to enable cross-channel and interest-based advertising. The App makes those requests directly from your device, so the network or mediator receiving a request also sees your device’s IP address, as any service your device connects to does. Our servers do not share or sell your IP address. Unless you have opted out under Section 10 or we have identified you as under 18, a mediator such as Google Ad Manager or Nimbus may include your IP address when it passes a request on to the additional advertising companies it works with. The App may separately send a hashed (one-way) form of your email address to our identity resolution provider for the sole purpose of obtaining the RampID described in Section 3. Neither the App nor PhotoCircle provides your email address to advertising networks, or a hashed form of it to anyone other than that provider. This information is shared solely for advertising purposes related to your use of PhotoCircle, and not for those partners’ independent marketing of their own products and services.

Affiliates and Service Providers. We share your information with our third-party service providers, affiliates, and any subcontractors as required to offer you our products and services. The service providers we use help us to:

Some external service providers may also collect information directly from you (for example, a payment processor may request your billing and financial information) in accordance with their own privacy policies. These external service providers do not share your financial information, like credit card number, with us, but may share limited information with us related to your purchase, like your zip code.

Location Metadata Within Circles. Location metadata preserved with your Media, as described in Section 2, is included in copies downloaded by other Users of any Circle where the Media is shared; remove it before uploading if you do not wish to share where your Media was captured.

Service Providers and Recipients. We share data with the following providers:

We seek to work with service providers who handle personal information in accordance with applicable privacy laws and limit their use of your data to the purposes described in this Privacy Policy.

Aggregated Data. We may also aggregate or otherwise strip information of all personally identifying characteristics and may share that aggregated, anonymized data with third parties or publish it. We reserve the right to make use of any such aggregated data as we see fit.

Disclosures Required by Law. We disclose your information to law enforcement and other public authorities in response to valid legal process and in emergencies, as described in Section 11. We may be under a duty to disclose or share your personal information to comply with any legal obligation, to enforce or apply our terms and conditions and other agreements, to protect our rights, property, or safety, or to protect the rights, property, or safety of others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.

Third Party Marketing. PhotoCircle does not share your personal information with third parties for their own direct marketing purposes. Ad Identifiers may be shared with advertising networks, and a hashed form of your email address with our identity resolution provider, to serve advertising related to your use of PhotoCircle, not for those parties’ independent marketing use.

Content Moderation. In limited circumstances, your uploaded photos may be scanned using automated tools (such as PhotoDNA) to detect known child sexual abuse material. If a match is detected, the photo and associated metadata may be flagged and reviewed internally and reported to the National Center for Missing and Exploited Children (NCMEC) as required by U.S. law. These moderation tools do not allow PhotoCircle or its vendors to see or extract your original photos unless flagged.

5. Do Not Track

Our Site does not currently respond to all Do Not Track signals, as we are awaiting consensus from the Internet policy and legal community on the meaning of Do Not Track and the best way to respond to these signals.

Separately from Do Not Track, we honor Global Privacy Control (GPC) signals on our Site. Where we receive a GPC signal from your browser, we treat it as a request to opt out of the sale or sharing of personal information for that browser, as described in Section 10.

6. Cookies

To make certain aspects of our Services work, we may request placing small data files called cookies on your device. A cookie is a text file that a service saves on your device. The cookie enables the service to remember your actions and preferences (such as login, shopping cart, etc.) over a period of time, so you do not have to keep re-entering them whenever you come back to the service. To learn more, please see our Cookie Policy.

Google Analytics. We may use Google Analytics. We use the information we get from Google Analytics only to improve the Site. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Please refer to Google’s Privacy Policy for more information. You may also choose to download the Google Analytics opt-out browser add-on.

7. Family Educational Rights & Privacy Act (FERPA)

Some of our customers may include public schools and institutions. In the United States, FERPA restricts the disclosure of personally identifiable information from a student’s education records, unless an exception applies. Our data protection and privacy policies and practices support such customers in complying with FERPA. For example, if a public school or institution uses our services for students, we maintain the privacy of those student Users and only use that information to deliver our services.

Students and parents of students may have specific rights under FERPA related to access and/or updating the students’ information. Students and parents (where applicable) may edit their personal information by accessing their account and updating their information.

8. Privacy Rights & Additional Disclosures for EEA, UK & Swiss Individuals

Lawful Bases for Processing (EEA, UK & Swiss Individuals). If you are from the European Economic Area (EEA), the United Kingdom (UK), or Switzerland, our legal bases for collecting and using your personal information are as follows:

We also rely on a combination of legitimate interests, legal obligations, and, where required, user consent to scan content or respond to content flagged by automated moderation tools. For example, when scanning images to detect child sexual abuse material (CSAM) using PhotoDNA, our basis may be a legitimate interest to prevent serious crime and protect our community from harm. Where local laws require consent or judicial authorization to perform such scanning, we comply with those requirements. You may object to this type of processing where applicable under law.

Where we confirm your age and apply the age-appropriate settings described in Section 14, we rely on compliance with our legal obligations under child-protection and data-protection laws that set a minimum age for using services like ours and, where no specific legal obligation applies, on our legitimate interest in ensuring that the Services are used only by people who have reached the applicable minimum age and in protecting Users under the age of 18. We do not rely on your consent for this processing.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided at the end of this Privacy Policy.

Where we process precise geolocation data contained in the metadata of Media you upload, we rely on our legitimate interests in keeping the capture date and location with your Media, including in the copies you and other members of your Circles download, and in offering location-related features, such as organizing, searching, and displaying Media by where it was taken, as we add them. We do not use this data to build a profile of you, to draw inferences about you, or for advertising, and we do not sell it or share it for advertising. You can prevent us from collecting it by disabling location tagging on your device or by removing location metadata before upload, as described in Section 2. Where we process such data for safety, security, or legal-compliance purposes, we may also rely on our legitimate interests or a legal obligation. You may object to this processing where applicable under law.

Ad Identifiers. Where the App sends a hashed form of your email address to our identity resolution provider to obtain a RampID, and where the App includes Ad Identifiers in the ad requests it makes to advertising networks, we rely on the consent you give through the prompts in the App. You may withdraw that consent at any time through those prompts.

Where we and our advertising partners show you non-personalized ads, and where we filter invalid traffic, we rely on our legitimate interests in funding the free Services and protecting our advertising from fraud.

Your Privacy Choices. The advertising opt-out described in Section 10 is available to you wherever you live, including in the European Economic Area, the United Kingdom, or Switzerland, in addition to any consent you give or withhold through the prompts in the App.

EEA, UK and Swiss Individuals’ Rights. If you are from the EEA, UK, or Switzerland, you have the right, under certain circumstances, to:

To exercise any of these rights, contact us using the contact details provided at the end of this Privacy Policy, and please specify which privacy right(s) you wish to exercise. We may need to verify your identity to honor your request.

Right to Lodge a Complaint. If you have any issues with our compliance, you have the right to lodge a complaint with an EEA supervisory authority. We would, however, appreciate the opportunity to first address your concerns and would welcome you directing an inquiry to us via the contact information at the bottom of this Privacy Policy.

EU and UK Representative. We value your privacy and your rights as a data subject and have therefore appointed Prighter Group with its local partners as our privacy representative and your point of contact for the following regions:

Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data). If you want to contact us via our representative, Prighter or make use of your data subject rights, please visit the following website: https://app.prighter.com/portal/14797230048.

Data Privacy Frameworks & International Transfers of Data. We may transfer information from or about you or your devices to countries other than the country where you are located (including to the United States), which may not have the same data protection laws as your jurisdiction. The Data Privacy Frameworks govern transfers of personal data protected by EU data-protection law, including the General Data Protection Regulation (GDPR), UK data-protection law, and Swiss data-protection law. For more information regarding our compliance with the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, and the Swiss-U.S. Data Privacy Framework to authorize these data transfers, please review the following disclosures.

PhotoCircle complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF (“UK-U.S. DPF”), and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) (collectively, the “DPF”) as set forth by the U.S. Department of Commerce.

PhotoCircle has certified that it adheres to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles”) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. PhotoCircle has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (“Swiss-U.S. DPF Principles”) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles (collectively, the “DPF Principles”), the DPF Principles shall govern. To learn more about the DPF program, and to view our certification, please visit https://www.dataprivacyframework.gov.

With respect to personal data received or transferred pursuant to the DPF, PhotoCircle is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission.

Pursuant to the DPF Principles, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under the DPF should direct their query to privacy@photocircleapp.com. If requested to remove data, we will respond within a reasonable timeframe and process deletion in accordance with the retention periods and exceptions described in Section 13.

We will provide an individual opt-out or opt-in choice before we share your data with third parties other than our agents, or before we use it for a purpose other than that for which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to privacy@photocircleapp.com.

As explained in this Privacy Policy, we sometimes provide your information to third parties to perform services on our behalf. If we transfer personal information received under the DPF to a third party, the third party’s access, use, and disclosure of the personal data must also be in compliance with our DPF obligations, and we will remain liable under the DPF for any failure to do so by the third party unless we prove we are not responsible for the event giving rise to the damage. We may be required to disclose personal information that we handle under the DPF in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

DPF Complaints Involving Personal Data We Process as a Controller. For EU, UK, and Swiss individuals with inquiries or complaints regarding our handling of personal data received or collected as a controller in reliance on the EU-U.S. DPF, the UK-U.S. DPF, and the Swiss-U.S. DPF, please first contact us at: privacy@photocircleapp.com.

If your DPF-related complaint cannot be resolved through this channel, PhotoCircle commits to refer unresolved complaints to JAMS DPF Dispute Resolution, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, please visit DPF Dispute Resolution for more information or to file a complaint. The services of JAMS DPF Dispute Resolution are provided at no cost to you.

If your DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See DPF Annex 1 at https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction.

9. Privacy Rights & Additional Disclosures for Certain US State Residents

Several jurisdictions grant state residents certain rights and disclosures. Depending on your state of residence, you may have specific rights regarding your personal information under applicable state privacy laws. We provide the following information to further help you understand your potential privacy rights. To exercise any of the rights described below, please contact us at privacy@photocircleapp.com or use the account settings within the App.

Your Rights. Subject to certain exceptions and limitations, residents of states with comprehensive privacy laws may have the right to:

Request for Information or Deletion of the personal information we have collected about you.

Residents of certain US states have the right to know whether we are processing your personal information, and in some instances, you have the right to request that we disclose to you the categories listed below for the preceding 12 months. In responding to this right, we shall provide to you:

In addition, you may have the right to request we delete your personal information. When we delete information in response to your request, we do so in accordance with the retention periods and exceptions described in Section 13.

Request for Correction of inaccuracies in your personal information.

Residents of certain US states have the right to request correction or rectification of inaccurate information in the resident’s personal information.

Request a portable copy of your personal information.

Residents of certain US states have the right to receive, in certain circumstances, a portable format of their personal information that allows the data to be transmitted to another entity.

Do Not Sell or Share My Personal Information. Residents of certain US states have the right to opt out of the sale or sharing of their personal information. We describe that right, what we share, and how to exercise it in Section 10, “Your Privacy Choices.”

Limiting the Use of Sensitive Personal Information. Residents of California have the right to direct us to use or disclose sensitive personal information only for providing goods or services, or as otherwise minimally permitted under applicable law. However, we do not disclose sensitive personal information for any purpose other than providing our goods and services to you, or as otherwise minimally permitted under applicable law.

Automated Processing & Profiling. Residents of certain US states have the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects. However, we do not process your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects.

How to Exercise Your Rights. To exercise any of the rights described above, please contact us at privacy@photocircleapp.com or use the account settings within the App.

Verification. To protect our consumers’ privacy, we may verify privacy rights requests to ensure that only you (or your authorized agent) can exercise rights pertaining to your personal information. As part of our verification process, we may request you to submit additional information.

Authorized Agents. You may designate an authorized agent to submit requests on your behalf. We may require the authorized agent to provide proof of your written permission and may need to verify your identity directly.

If you are an authorized agent wishing to exercise rights on behalf of a state resident, please contact us using the information at the bottom of this Privacy Policy and provide us with a copy of the consumer’s written authorization designating you as their agent.

Right to Appeal. In certain cases, we may decline to take action on your request, as permitted by law. If we decline to take action on your request, you may appeal that decision by contacting us at privacy@photocircleapp.com with the subject line “Privacy Appeal.”

If we deny your appeal, we may provide a written explanation of our decision with instructions on how to contact your local Attorney General or Department of Justice for further review, where permitted under certain US state privacy laws.

Non-Discrimination. You have the right to receive equal service and price, even if you exercise a privacy right. We will not discriminate against you for exercising your privacy rights.

10. Your Privacy Choices (Do Not Sell or Share)

We never sell or share your name, your email address (other than a hashed form described below), the photos and videos you upload, your comments, or the contents of your Circles with advertisers or advertising networks.

What we do share is narrower. When you use the free, ad-supported version of the App, it includes the Ad Identifiers described in Section 3 in its ad requests and may send a hashed form of your email address to LiveRamp, as Section 4 describes. Under the California Consumer Privacy Act (CCPA/CPRA) and similar laws in other states, this may count as “sharing” or, in some states, “selling” personal information, even though no one pays us for your information itself — our revenue comes from the ads shown in the App — and no directly identifying information reaches an advertiser.

You have the right to opt out at any time, wherever you live — this choice is not limited to residents of any particular state or country. You can opt out by:

Declining tracking on iOS limits the Ad Identifiers the App can use and keeps ads non-personalized, but it does not, by itself, opt you out of sale or sharing under this Section.

Once you opt out, the App stops sending a hashed form of your email address to our identity resolution provider and discards any RampID it holds for you. The App also tells each advertising partner or mediator that you have opted out whenever it requests an ad, with our requirement that they use your Ad Identifiers and IP address only to show and measure non-personalized ads and not share them with the additional advertising companies they work with. You will still see ads in the free version of the App, but they will not be personalized. Your opt-out will be honored for as long as your account exists and will not be reversed by reinstalling the App, signing out, switching devices, or letting your session expire — only an explicit action by you will resume sharing.

If we have identified you as under the age of 18, we apply this setting for you automatically. The App does not send a hashed form of your email address to our identity resolution provider, and it tells each advertising partner or mediator that you are under 18, with our requirement that they use your Ad Identifiers and IP address only to show and measure non-personalized ads and not share your information onward. You will only see non-personalized ads, and the setting cannot be switched off. See Section 14 for the other protections that apply to Users under 18.

You can also opt out directly with LiveRamp at liveramp.com/opt_out/.

If you have questions about these choices, contact us at privacy@photocircleapp.com.

Notwithstanding any provisions regarding data retention and deletion, PhotoCircle complies with all legal reporting obligations under U.S. federal law, including 18 U.S.C. § 2258A, and the UK Online Safety Act. If we become aware of potential CSAM or other criminal content:

These disclosures are not subject to user consent and override any conflicting data deletion requests.

Cooperation with Law Enforcement. We cooperate with law enforcement and other government authorities investigating crimes, threats to the safety of children or adults, and other unlawful activity. When we receive a subpoena, court order, search warrant, or other valid legal process, we comply with it and provide the information it calls for, which may include account information, records of activity, and the contents of your account. We will also disclose information without waiting for legal process where the law allows, including where we believe in good faith that an emergency involves danger of death or serious physical injury to any person.

Preservation. When law enforcement asks us to preserve information while it obtains legal process, we preserve it. That preservation overrides any deletion request or retention period in Section 13 for as long as the request or the law requires.

No Notice to You. We are not obligated to tell you, or any Customer whose Workspace you belong to, that we have received a request for your information or how we responded, and we may choose not to. Where a court order or law prohibits notice, we will not give it.

12. How We Secure Your Information

Like most applications today, we use cloud server infrastructure to run our App and Website. We license server spaces that encrypt data sent to the App and displayed by the App, both while “at rest” in our database and “in transit” between the App and those databases. Only we can access the database(s) we created to operate the App, and we do so only through accounts approved and provisioned for senior security engineers on our team. The service provider who supplies the database infrastructure does not have access to the data we store there.

When we generate QR codes or links to add members to a Circle, we share these only with the user and device that requested them. You choose who to share them with from there.

Note that SSO information is controlled and accessed by the relevant SSO provider, such as Google, Microsoft, or Apple. Please refer to the privacy policies of these platforms for more information about how they operate their SSO.

While we take reasonable precautions against possible security breaches of the Website, PhotoCircle and our customer databases and records, no website or Internet transmission is completely secure, and we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. We urge you to use caution when choosing what information to share with us.

13. How We Retain Information

We retain information from or about you only for as long as necessary to fulfill the purposes described in this Privacy Policy or, where we process information on behalf of a Customer, the Customer-instructed or controller-directed purposes for which we process it, subject to the specific deletion windows and exceptions below.

When you delete individual content while keeping your account active, we delete the corresponding primary records immediately and create an audit-history record of that deletion. For active accounts, audit-history records that support restoration may be retained for up to 91 days from the date each audit-history record is created.

When you delete your account, or a Customer instructs us to delete information we hold on its behalf, we delete the primary data immediately and create an audit-history record of that deletion. Audit-history records concerning the deleted account or information are deleted within 31 days after the deletion or instruction. An audit-history record that instead documents an action taken on another User’s still-active account remains part of that other account’s audit history, retained for up to 91 days from the date it was created.

Stored objects such as photos, videos, files, profile photos, and Workspace branding images are physically purged within 89 days after they become unreferenceable. “Unreferenceable” means that no link to the stored object remains in any primary record or audit-history record, including records associated with other Users. Because PhotoCircle uses distributed and deduplicated storage, a stored object may remain while another User or record lawfully references the same object (for example, if two Users have uploaded the exact same photo), and physical purge can occur after account data and audit-history records have been removed. This storage architecture does not limit your rights under Sections 8 and 9 or any Customer-directed rights process that governs your data.

Database backups may retain copies of deleted or changed information for up to 91 days from the date each backup is created. Records held for us by the service providers listed in Section 4, such as support conversations, payment records, and error and delivery logs, are retained under those providers’ terms. Any RampID or similar advertising identification code is held only by the App on your device, never on our servers, and the App discards it when you opt out under Section 10 or when we have identified you as under the age of 18.

The capture date and location kept with Media are treated as part of the associated Media’s primary records and are deleted on the same schedule, unless you remove them or delete the associated Media sooner.

The age information described in Section 14 (your recorded age, its source, and the date we recorded it) is part of your primary account records. We keep it for as long as your account exists and delete it on the same schedule as your other account data. When an account is deleted because the User has not reached the applicable minimum age, these same windows run from the date of that deletion.

For individuals protected by the GDPR (General Data Protection Regulation), the UK GDPR, or Swiss data-protection law, these retention periods are designed to support erasure without undue delay under Article 17 and storage limitation under Article 5 while preserving the resilience and protection against data loss that Article 32 requires; the longer windows for backups and unreferenceable stored objects reflect that balance. The same windows apply to every User regardless of location.

These deletion windows are subject to specific exceptions. Notwithstanding any deletion request or retention period, PhotoCircle preserves and discloses information where required for CSAM or other legal reporting and preservation obligations described in Section 11. We may also retain information to comply with mandatory legal obligations, including inappropriate content reports and moderator logs retained for compliance with the UK Online Safety Act and other relevant legislation, and the banned-account email hash described below.

When an account is permanently banned, we may retain a non‑reversible, salted hash of your email address. This salted hash is used solely to prevent subsequent re‑registration under a new account by previously banned individuals. The hash is pseudonymized, cannot be reversed to reveal your email address, and is not linked with any other personal data. We retain it only for the duration necessary to enforce the ban, in accordance with our legitimate interest for platform safety.

14. Children’s Privacy

Minimum age. You must meet the minimum age required to use PhotoCircle in the country, state, or province from which you access the Services. That minimum age is 13 in most places and higher in some, and it is set by the law that applies where you are. PhotoCircle is not directed to children below the applicable minimum age, and we do not knowingly allow them to create or keep an account.

How we confirm your age. Where your device’s operating system or app store makes an age signal available to us, we use it. Where it does not, we ask you for the month and year of your birth. We use your answer only to work out your age, and we do not store it. What we keep is a single age: the youngest you could be, based on the information available to us. Anyone 18 or older is recorded simply as 18. We keep it together with where that information came from (your app store or you) and the date we recorded it. Because we keep that date, your recorded age moves forward on its own, and you will not be asked again as you get older. We never ask you for a government-issued identity document, a selfie, a photo of a document, or a payment card to confirm your age, and we do not keep a separate history of previous ages beyond the audit records described in Section 13. We work out which minimum age applies to you from the location of your internet connection each time you use the Services. PhotoCircle uses the IP2Location LITE database for IP geolocation. We do not keep a record of where you live. Your IP address is one of the identifiers we collect under Section 2 and is kept with your sign-in records, and our usage statistics record only which regional age rule applied.

We use this information only to confirm that you are old enough to use the Services, to apply the age-appropriate settings described below, and to meet our legal obligations. We do not share your recorded age with advertising or analytics partners, except that the App signals to advertising partners that a User is under 18 so that personalized advertising is switched off.

Checking again. If your recorded age came from your app store, the App checks the store for an updated signal periodically, without asking you anything. A store-sourced age also expires after a year, because store signals can lag behind a person’s actual age; if the store then provides no signal, we may ask you for your birth month and year. An age you gave us yourself is kept, and you will not be asked again. You cannot change your recorded age in the App or on the web; if you believe it is wrong, contact us at support@photocircleapp.com.

If you are below the minimum age. If we learn that you are under 13, we suspend your account immediately and delete it, with its associated information, the next day, in accordance with the retention periods and exceptions described in Section 13. If you are 13 or older but below the minimum age where you are, we suspend your account once you have gone 30 days without using the Services from somewhere your age is allowed; if the suspension is not resolved within 30 days, we delete the account and its information in the same way. In either case we sign you out and email you to explain what happened and how to reach Support. If you are 13 or older and your account does not belong to a Workspace, that email includes a link to download your content and close the account during the suspension, without signing in. If you believe your recorded age is wrong, contact us at support@photocircleapp.com before the account is deleted and we will correct it.

Users under 18. Where we have identified a User as under the age of 18, we apply additional protections automatically. We do not use their information for personalized advertising: the App does not send a hashed form of their email address to our identity resolution provider, and it tells each advertising partner or mediator that the User is under 18, with our requirement that they use the User’s Ad Identifiers and IP address only to show and measure non-personalized ads and not share the User’s information onward. They see only non-personalized ads, and the Your Privacy Choices setting is applied for them and cannot be switched off, as described in Section 10. We do not send them marketing email, survey prompts, or re-engagement notifications. We also remove location metadata from Media they upload before it is stored. These protections are applied by us and do not require any action by the User.

If you are a parent or legal guardian with questions about a minor’s use of the Services, or if you believe we have collected information from someone below the applicable minimum age, or you find someone is using the App to upload photos of a child for whom they are not a guardian and do not have the appropriate legal guardian’s consent, please contact us at support@photocircleapp.com or privacy@photocircleapp.com with a description of the issue. Parents and legal guardians may also contact us at support@photocircleapp.com to ask about, or to request the removal of, a minor’s account.

Moreover, Customers, including entities covered by FERPA, may provide PhotoCircle access to students in accordance with the Customer’s privacy policies and practices, subject to the minimum age requirements described above. We will maintain the privacy of those Users and only use that information to deliver our services, as instructed by the Customer.

15. Change of Control

Information may be transferred to a third party because of a sale, acquisition, merger, reorganization, or other change in control. If we sell, merge, or transfer any part of our business, part of the sale may include your information.

16. Account Deletion

You can delete your account and data from the Account section of the app’s settings panel. Alternatively, you can email us at support@photocircleapp.com to request account deletion. Account deletion follows the retention periods and exceptions described in Section 13. Workspace User accounts are managed by the Customer and cannot be deleted from the App; contact your Workspace administrator. Please review our FAQ for more details.

17. Policy Updates

This Privacy Policy may be periodically updated. We encourage you to periodically review this Privacy Policy to ensure you are familiar with the most current version. Please review carefully before submitting personal information to our Site. The date the Privacy Policy was last updated is indicated at the top of this page.

18. Contact Us

Questions or concerns? Reach us anytime at privacy@photocircleapp.com