Privacy Policy and Anti-Corruption Policy

The Fine Print

Privacy Policy

Ballerton B.V. dba The Cirqle and The Cirqle.  (www.thecirqle.com) as well as any present or future affiliated or related
company (“The Cirqle” or “we”), recognizes the importance of your privacy. This privacy policy tells you what personal
information we collect and how we use it. The Cirqle may change this privacy policy from time to time, in its sole discretion,
as discussed below under “CHANGES TO THIS POLICY”, it’s the last section of this policy. By using or visiting any The
Cirqle website, application, product, software, tool, data feed, and/or service (collectively the “Service”), you understand and
agree to the terms of this policy.

What is personal information?

Personal Information is information relating to an identified or identifiable natural person. An identifiable natural person is
one who can be identified, directly or indirectly, by reference to an identifier such as a name, an identification number,
location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic,
cultural or social identity of that natural person.
We do not consider personal information to include information that has been anonymized or aggregated so that it can no
longer be used to identify a specific natural person, whether in combination with other information or otherwise.
We collect personal information from you when you use our Services.

Non-Personally Identifiable Information
We may collect non-personally identifiable information about you when you visit the Website. Non-personally identifiable
information may include technical and measurement information concerning, for example, your connection to and usage of
the Website. We may use this information for internal purposes, such as, usage analysis and improving the Website. This
information does not include your Personal Information

What do we do with information we collect?

Except as disclosed in this privacy policy, The Cirqle does not share your personal information with any outside parties.

The Cirqle will use the personally identifiable information directly provided by you solely for the purpose for which you have
provided it, whether it be to register, use the Service, communicate with others, request information, etc. We may also use the
information you provide to contact you for reasons related to use of the Service.

Disclosure: As a general rule, The Cirqle will not disclose any of your personally identifiable information except under one
of the following circumstances: we have your permission; we determine in good faith that it is legally required to be revealed
by any relevant statute, regulation, ordinance, rule, administrative or court order, decree, or subpoena; information revealed
during the course of The Cirqle’s enforcement of the policies and procedures of the Service, its application, and/or website;
information that we determine must be disclosed to correct what we believe to be false or misleading information or to
address activities that we believe to be manipulative, deceptive or otherwise a violation of law; where you are otherwise
notified at the time we collect the data; where we need to share your information to provide the product or service you have
requested; when such disclosure is made subject to confidentiality restrictions in connection with a sale, merger, transfer,
exchange, or other disposition (whether of assets, stock, or otherwise) of all or a portion of the business conducted by The
Cirqle.

How we protect personal information

We take appropriate organizational and technical measures to protect the data provided to us or collected by us, and do not
retain it any longer than permitted in order to perform our services or as required under relevant legislation, with due
observance of the applicable obligations and exceptions under the relevant legislation. You should be aware that internet
communications are not always secure. You are responsible for maintaining the security and confidentiality of your account
passwords. It is a condition of your use that you agree we are not liable for any such disclosure.

How we use your personal information
We use the personal information we collect from you for a range of different business purposes and according to different
legal bases of processing. The following is a summary of how and according to which legal bases we use your personal
information.


We use your personal information to fulfill a contract with you and provide you with our Services, to comply with our legal
obligation, protect your vital interest, or as may be required for the public good.
This includes:


- To provide payment processing and account management, operate, measure and improve our Services, keep our
Services safe, secure and operational, and customize site content that includes items and services that you may like
in response to actions that you take

- To contact you regarding your account, to troubleshoot problems with your account, to resolve a dispute, to collect
fees or monies owed or as otherwise necessary to provide you customer service
- When contacting you for such purposes as outlined above, we may contact you via email, telephone, SMS/text
messages, postal mail, and via mobile push notifications
- When contacting you via telephone, to ensure efficiency, we may use autodialed or pre-recorded calls and text
messages as described in our User Agreement and as authorized by applicable law. Message and data rates may
apply
- To provide other services requested by you as described when we collect the information
- To prevent, detect, mitigate, and investigate fraud, security breaches or other potentially prohibited or illegal
activities
- To enforce our User Agreement

We use your personal information to pursue our legitimate interests where your rights and freedoms do not outweigh these
interests. We have implemented controls to balance our interests with your rights. This includes to:

- Improve our Services, for example by reviewing information associated with stalled or crashed pages experienced
by users allowing us to identify and fix problems and give you a better experience
- Personalize, measure, and improve our advertising based on your advertising customization preferences
- Contact you via email or postal mail in order to offer you coupons, discounts and special promotions, poll your
opinions through surveys or questionnaires and inform you about our Services, as authorized by applicable law
- Contact you about public policy matters, or other current events, related to your ability to use our Services. This
could include an invitation to join a petition, letter writing, call or other sort of public policy related campaigns.

We use your personal information to to comply with our legal requirements, enforce our User Agreement, respond to claims
that a listing or other content violates the rights of others, or protect anyone's rights, property or safety

We use your personal information to respond to law enforcement or governmental agencies, or authorized third-parties, in
response to a verified request or legal process relating to a criminal investigation or alleged or suspected illegal activity or
any other activity that exposes us, you, or any other of our users to legal liability. We will only disclose information we deem
relevant to the investigation or inquiry, such as name, city, state, postcode, telephone number, email address, User ID history,
IP address and fraud complaints

How far does our responsibility extend?

This Privacy Policy applies to services that are owned and operated by us. It does not necessarily apply to sites our customers
create using our software, even if operated by us. We do not exercise control over other users or third party websites that may
link to our Service. They may place their own or other files on their website, collect
data or solicit personal information from you. We accept no responsibility or liability for these other sites or services. Third
party websites

You may have the option to register using a third party service (“TPS”) or connect your account to a TPS, such as Instagram,
Facebook, Twitter or YouTube. By authorizing us to access your TPS account, you understand that we may obtain certain
information from your TPS account, which may including your name, email address, birthday, work history, education
history, current city, shared media, and the names, profile pictures, relationship status, and current cities of your TPS
contacts. We only obtain information from your TPS account that you specifically authorize and grant us permission to
obtain.

We do not control the content or links that appear on these sites and are not responsible for the practices employed by
websites linked to or from our Site. In addition, these sites or services, including their content and links, may be constantly
changing. These sites and services may have their own privacy policies and customer service policies. Browsing and
interaction on any other website, including websites which have a link to our Site, is subject to that website’s own terms and
policies.

Children's privacy

Our Sites are not directed to children and we will not request personally identifiable information from anyone who we know
to be under the age of 18, unless we have obtained verifiable parental consent from a parent or legal guardian. If we become
aware that a user under the age of 13 has registered with any of our Sites, provided personally identifiable information, and
The Cirqle has not obtained prior verifiable consent from a parent or legal guardian, we will immediately remove the user’s
personally identifiable information from our files.

Cookies
We may collect information Personally Identifiable Information about you left on The Cirqle website in cookies. These are
for your convenience so that you do not have to fill in your details again. These cookies will last for one year.  A "cookie"
stays on your computer until it is deleted and you can remove them by following the directions provided in your browser's
"help" files.  When you use our site we may store cookies on your computer in order to facilitate and customize your use of
our site. A cookie is a small data text file, which a website stores on your computer's hard drive (if your Web browser

permits) that can later be retrieved to identify you to us. Our cookies store randomly assigned user identification numbers, the
country where you are located, and your first name to welcome you back to our site. The cookies make your use of the site
easier, make the site run more smoothly and help us to maintain a secure site. You are always free to decline our cookies if
your browser permits, but some parts of our site may not work properly in that case. We may use an outside ad serving
company to display banner advertisements on our site. As part of their service, they will place a separate cookie on your
computer. We will not provide any third-party ad server with any of your Personally Identifiable Information or information
about your use of our website.

What rights do you have?

If you would like to exercise your right to view, correct, complete or remove your Personal Data, please contact us
at support@thecirqle.com  or request the deletion of your account (including Personal Data) in your dashboard. Upon
verification of your identity, we will attempt to quickly fulfill your request, provided we will not act contrary to applicable
legislation by fulfilling your request.  Any recipient of email notices may opt out of receiving them at any time. To opt out of
receiving emails,  follow the  unsubscribe instructions  located  near the  bottom of  each  service update,  newsletter,  or
promotional email, or email your request to support@thecirqle.com

Contact us

If you have any questions or concerns about this Policy, please feel free to contact us any time through the sites or at Privacy
Policy Concerns, c/o Ballerton B.V..  Lauriergracht 160 1016RV Amsterdam, The Netherlands

Changes to this policy

We reserve the right to change the terms of this privacy policy at any time. When we make changes, we will revise the “last
updated” date at the top of the policy. If there are material changes to this statement or in how we will use your personal
information, we will notify you by prominently posting a notice of such changes here or on our home page, or by sending you
an email. We encourage you to review this policy whenever you visit one of our websites or applications.

Anti-Corruption Policy

Introduction

The Cirqle is committed to conducting business in an ethical and transparent manner. This Anti-Corruption Policy (“Policy”) outlines The Cirqle’s stance on corruption and provides guidelines for employees, contractors, and partners to ensure compliance with anti-corruption laws and regulations.

Scope

This Policy applies to all employees, contractors, officers, and directors of The Cirqle (“Representatives”). It also applies to third parties, including vendors, partners, and agents acting on behalf of The Cirqle.

Policy Statement

The Cirqle prohibits all forms of corruption, bribery, kickbacks, and other unlawful or unethical financial practices.

Bribery: Representatives must not offer, give, request, or accept any form of bribe, kickback, or unlawful incentive to or from any person or organization, including government officials and private sector employees.

Gifts and Hospitality: Representatives may not offer or accept gifts or hospitality aimed at obtaining or retaining business advantages.

Facilitation Payments: The Cirqle does not allow “facilitation” or “grease” payments, which are small payments made to expedite routine governmental actions.

Third Parties: Due diligence must be conducted before engaging with third parties. Representatives must ensure that third parties adhere to this Policy.

Record-Keeping: All financial transactions must be accurately recorded in The Cirqle’s books and records.

Responsibilities

Compliance: Representatives are responsible for understanding and complying with this Policy and any related procedures.

Training: Employees will be provided with training on this Policy as part of their induction and will receive periodic refresher training.

Reporting: Any suspicion of corruption should be reported immediately through the designated whistleblowing channels.

Monitoring and Review: The Compliance Team will periodically review and update this Policy and related procedures.

Enforcement

Failure to comply with this Policy may result in disciplinary action, up to and including termination of employment or contract, as well as potential legal consequences.

Approval and Review

This Policy is approved by the Board of Directors and will be reviewed annually or as needed to ensure its effectiveness.

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