Last Modified: February 20, 2020
Welcome! CirclesX respects your privacy. CirclesX and its affiliates (“CirclesX” or the “Company”) provides an online marketplace (the “Platform”) for people who want to make binding, tradable commitments to pre-buy, pre-sell, or even re-sell “stuff,” which could include, for example, physical products; service offerings; the right, at specified times, to occupy space in cars, trucks, buses, trains, garages, streets, sidewalks, classrooms; and potentially lots of other things.
Who is “CirclesX” (the company) CirclesX companies: For purposes of this Agreement, the term “CirclesX” refers to one of two companies, depending on where you are using the Platform.
(a) If you are using the Platform within the United States and its territories, then the term “CirclesX” refers to SimpsX Technologies LLC, a Delaware limited liability corporation, which has offices at 12335 Kingsride #418, Houston, Texas, 77024.
(b) If you are using the Platform elsewhere, then the term “CirclesX” refers to SimpsX Technologies Cayman Limited, with offices at Walkers, PO Box 908 GT, Walker House, George Town, Grand Cayman, Cayman Islands, British West Indies.
The information that CirclesX collects from users;
How that information is used by CirclesX; and
The rights and options available to users.
The Services are not intended for use by persons under the age of 13. If you are under 13, you may not download or use the Application.
Contact CirclesX/ Abuse reports
If you believe that your privacy has been compromised by any person, in the course of using the Services, then please contact CirclesX at: privacy@CirclesX.com
You may send CirclesX other requests, responses, questions and complaints by email at support@CirclesX.com
Information that is being collected
The categories of information collected by CirclesX will include all or just some of the following, depending on how you choose to use the Services.
Once you installed the Application on your device, CirclesX will collect:
Detailed location and route information, for example in the form of GPS signals and other information sent by your mobile device on which the Application is installed and activated. CirclesX uses this location and route information to create a detailed location history of all of the journeys you have made while using the Application; and
Information about your use of the Services and the device on which the Application is installed, as explained in the section “Meta-data that we collect”, below; If you choose to use the Services in a manner detailed below, CirclesX may also collect:
Information that you choose to share with CirclesX, including a username you have chosen, reports associated with your username, “home” or “work”, “my routes”, other “favorites”, destinations you may travel to, chat messages, search queries, calendar information, files you have uploaded to the service, including voice, video and audio files, if applicable. In addition, if you choose to opt in to the “find CirclesX friends” feature CirclesX will collect:
Periodically, all of the phone numbers which are stored on your device’s phone book . We only collect numbers in a form which is anonymous to CirclesX, we may also collect names, addresses or other information from your device’s phone book. This information will be used as part of the “find CirclesX friends” feature to help find and create a list of other CirclesX users who you may know and with whom you may wish to connect; and/or
Your phone number. Your phone number will be used to verify your account and as part of the “find CirclesX friends” feature to help find and create a list of other CirclesX users who you may know and with whom you may wish to connect. See here for more information;
Information required when setting up a username you have chosen, such as your name and gender. Bear in mind that false, incorrect, or out-dated information may impair CirclesX’s ability to provide you with the Services and to contact you when necessary. CirclesX will explicitly indicate the fields for mandatory completion. If you do not enter the requisite data in these fields, you may not be able to set up a username; and/or
Information shared from your social network accounts. See “Integration with social networks”, below.
In order to access certain features of the Services (for example transportation unit transactions, map editing, rating), you will need to set up a username.
If you do set up a CirclesX username and password in the Application:
CirclesX will link all of your information with your Account and that username. This includes information received from all mobile devices running the Application on which you have chosen to sign in using your username and password;
With the exception described in the bullet below, your Account and information associated with your Account will be visible only to CirclesX; and
When using the Application, your approximate location and other information you may choose to contribute will be visible to other users associated with that username.
If you do not set up a CirclesX username and password in the Application (by skipping the username setup stage of the application installation process):
CirclesX will still link all of your information with your Account and a unique identifier generated by CirclesX;
With the exception described in the bullet below, your Account and information associated with your Account (including your unique identifier) will be visible only to CirclesX; and
When using the Application, your approximate location and other information you may choose to contribute will be visible to other users associated with the username “CirclesX”.
Uses of information
CirclesX may use information collected from or provided by you for the following purposes:
To provide you with the Services. For example, CirclesX may:
Use your location and route information and/or search query history to provide navigation services and to provide information and advertisements about sites, shops and other places and attractions in your close vicinity, or that we believe, based on your search query history and metadata, you may find interesting; and
(If you have opted in to the “find CirclesX friends” feature), use your phone number and the phone numbers which are stored in your device’s phone book to find and create a list of other CirclesX users who you may know and with whom you may wish to connect. See here for more information.
To operate the Services and to improve and customize your experience with the Services. For example, CirclesX may use your “home” and “work” and “my routes” information or location history to offer routes based on how you’ve chosen to travel between favorite destinations in the past;
To improve the experience of other users. For example, CirclesX may use your route information to improve the accuracy of its mapping and navigation data;
To provide you with support and handle requests and complaints;
To send you updates, notices, announcements, and additional information related to the Services;
To create aggregated and/ or anonymous data (where such data does not enable the identification of a specific user). See “How does CirclesX use aggregated information”, below;
To conduct surveys and questionnaires;
To share your submissions with other users of the Services and to facilitate communication between you, CirclesX and other users;
To contact you when CirclesX believes it to be necessary;
To comply with any applicable law and assist law enforcement agencies under any applicable law, when CirclesX has a good faith belief that CirclesX’s cooperation with the law enforcement agencies is legally mandated or meets the applicable legal standards and procedures;
To prevent fraud, misappropriation, infringements, identity theft and other illegal activities and misuse of the Services;
To handle breakdowns and malfunctions;
To take any action in any case of dispute, or legal proceeding of any kind between you and the Service, or between you and other users or third parties with respect to, or in relation with the Service;
You may also provide additional information that will be used to personalize the Services and enhance your experience with the Services. For example, if you provide us with your “home” and “work” information, we may provide you with what we think is the shortest route between those locations.
Further information may be collected when CirclesX exchanges communications with you, for example, if you submit a request, contact CirclesX’s support team, or report a violation to the abuse team.
Personal information that you share
The Services are based on a community of users publicly sharing information with CirclesX and with other members of that community.
In particular, users choose to share personal information such as name, age, gender, picture, their location information, reports and other files. This information may be shared either directly to the Service and to all users, such as in the case of traffic reports, or just to your friends on CirclesX via the “find CirclesX friends” feature . This information may also be shared via third party services (such as social networks) which interact with the Service upon such users’ choice.
The content that you share to all users is neither private nor confidential and you should not have any expectation of privacy with respect to it. Information you upload will be posted along with other personal information. Certain road incidents you report may include your driving path within the vicinity of those incidents. Therefore, you must exercise caution and common sense when submitting information. At the very least you should demonstrate the same degree of caution as when publishing personal information by means other than the Internet and cellular services.
You can decide whether or not to upload content to the Services. However any content that you submit for posting, may be viewed by all users of the Services and by CirclesX.
In any event (but except as detailed below with respect to information shared from your social network accounts according to your privacy settings for such social network accounts), your email address will not be visible to others through any reports or user posts that you share or upload.
CirclesX collects voice information, including voice files if you either record your own voice, or use the voice command features. If, after recording your own voice, you chose to share your voice recordings, other CirclesX users and other people will be able to download and use your voice recordings. Once downloaded, CirclesX may not have any control over the voice files, so you should only share content that you are comfortable being made public.
We, at CirclesX, take great measures to provide you with the best experience you can have while using the Service. However, CirclesX has no control over the conduct of any user and disclaims all liability in this regard. Users are advised to carefully and thoroughly consider whether or not to make public or available any information and carefully examine all necessary details related to any communication with other users prior to any engagement or communication being made.
Participating in any user’s activities as a result, directly or indirectly, from using CirclesX, is entirely at your own risk. CirclesX is not a party to any agreement entered into between the users in any circumstances. The user has the sole and ultimate responsibility regarding compliance with all laws, regulation or any other duty. We do not accept any liability for any loss, damage, cost or expense that you may suffer or incur as a result of or in connection with your participation in any activity or event initiated, held or conducted by a user or a third party nor in connection to any agreement between the users or third parties, including any activity or event related in any way, directly or indirectly, the Services or the use thereof.
Integration with social networks
You may choose to share information between your Account and your social network account (such as Facebook, CirclesX, Google Plus, or others ). Through this option, you may choose to have personal information and other content about you available from social networks, transmitted and shared through the Services. Similarly, you may choose to have personal information and other content about you available from CirclesX, including your location and route information, transmitted to and shared through your social network account.
When you connect to the social network account through the Services for the first time or otherwise make the Services interact with your social network account, you will be asked to permit the social network to share your personal information stored on such social network with the Services. We collect your information from your social network account only in accordance with the permissions granted by you.
Accordingly we only collect such information which you allowed the social network(s) to share with third parties (such as your name, email address, list of friends, profile picture, other information available via the applicable social network). You understand and agree that the Services may access, make available and store (if applicable and as permitted by the third party social network) such information so that it is available on and through your Account, until your Account is deleted.
Please note that certain information which you have defined as private on your third party social network accounts may become public to other CirclesX Users through the Services once you have allowed the social network to share such information with CirclesX.
Integration with other third party services
CirclesX offers you the option to link CirclesX to third party services that may be useful to you. Where CirclesX detects an integration may be available (either because a third party service attempts to link to CirclesX, or CirclesX detects an installed service on the device which has an integration option, or you request a particular integration), CirclesX will ask for confirmation to connect the accounts. If you choose to connect the accounts and after connecting, CirclesX will ask for your permission to share data with the third party service. You should only agree to connect accounts if you are comfortable with the third party service receiving the data set out at the time of connecting the accounts and CirclesX is not responsible for the third party service’s use of data. You can disconnect CirclesX and the third party service at any time and CirclesX will cease sharing data with that service from the point of disconnection onwards.
Meta-data that we collect
CirclesX collects information about the use of the Services and information from the device you have CirclesX installed on. For example, CirclesX may record the frequency and scope of your use of the Services, the duration of your sessions, device name, operation system type, operating system version, battery usage, the web pages that you visit via the Application, information that you viewed, content that you use or create, advertisements that you view or click on, your communications with other users and third parties, the Internet protocol (IP) address and the name of the domain that serve you to access the Services, and the geographic location of the device that you are using to log-in and use CirclesX on.
Accessing the Services
In order to access certain features of the Services (for example, transportation Unit transactions, map editing, ratings), you will need to set up a username.
CirclesX may also establish and require from time to time additional or different means of identification and authentication for logging in and accessing the Services or for accessing certain features or designated sections of the Services.
Your log-in details are your responsibility. You are fully accountable for any use or misuse of your Account and personal details as a result of conveying your details to someone else. You must maintain your log-in details in absolute confidentiality and avoid disclosing them to others. Make sure that you change your password frequently and at least once every six months.
Sharing information with others
CirclesX does not sell, rent or lease your personal information to third parties.
CirclesX will not share your personal information with others, without your consent, except for the following purposes and to the extent necessary in CirclesX’s good-faith discretion:
As necessary for the operation of the Services. For example, making public road incidents you report and which are associated with your username and your location;
If CirclesX is required, or reasonably believes that it is required by law to share or disclose your information;
In any case of dispute, or legal proceeding of any kind between you and CirclesX, or between you and other users with respect to, or in relation with the Services;
In any case where CirclesX reasonably believes that sharing information is necessary to prevent imminent physical damage or damage to property;
For facilitating the Service and to store your data on servers located in the U.S.A and the European Union.
To collect, hold and manage your personal information through cloud based or hosting services or a third party or a party affiliated or connected to CirclesX, as reasonable for business purposes, which may be located in countries outside of your jurisdiction, including but not limited to the United States of America.
CirclesX may also share personal information with companies or organizations connected or affiliated with CirclesX, such as subsidiaries, sister-companies and parent companies. Personal information may also be shared with CirclesX’s other partners and service providers to process it for us, based on our instructions and in compliance with this policy and any other appropriate confidentiality and security measures.
Controlling your personal information
If you would like us to delete your Account, your username (if you have set one up) and your personal information, please use the “Delete Account” function we offer available under the Settings menu in the Application and on the Website.
On receiving such a request, CirclesX will use reasonable efforts to delete such information, however please note we may not delete information immediately from our back-up systems.
If you choose to set up a username, you can view your route history via the “Edit the Map”/ “Drives” function on the CirclesX website.
Your location and route history is associated with your Account and (if you have chosen to set one up) your username or (if you have chosen not to set up a username) the unique identifier generated by CirclesX.
If you find that the information associated with your Account is not accurate, complete or updated, then you must make all necessary changes to correct it. Please keep in mind that false, incorrect, or outdated information may prevent you from setting up a username and impair the ability to provide you with Services.
How does CirclesX use aggregated information?
CirclesX may use anonymous, statistical or aggregated information (including anonymous location information), in a form that does not enable the identification of a specific user, to properly operate the Services, to improve the quality of the Services, to enhance your experience, to create new services and features, including customized services, to change or cancel existing content or service, and for further internal, commercial and statistical purposes (including advertising).
CirclesX may also use anonymous, statistical or aggregated information collected on the Services, in a form that does not enable the identification of a specific user, by posting, disseminating, transmitting or otherwise communicating or making available such information to users of the Services, to the Services’ providers, partners and any other third party. For example, GPS information that we receive from your mobile device may be provided to map editors in an aggregated and/ or anonymous form to help improve the map and solve map problems, traffic data may be provided to cities, and ads analysis may be provided to advertisers.
Some of the cookies may expire when the session ends and you exit your browser. Other cookies are saved on your computer’s hard drive. If you wish to block the Website’s cookies, then please use the help button in your browser and follow the necessary instructions. However, bear in mind that disabling cookies may complicate or even prevent your use of the Website, or certain features thereof.
CirclesX may permit, solicit or contract certain other companies to conduct advertising campaigns on the Services.
The information and advertisements that you see when accessing the Services may be targeted on the basis of:
Information received from third party partners;
as well as your search query history.
You hereby agree that we may provide such information and advertisements targeted on the basis of your search query history. However, if, when accessing the Services, you no longer wish to see information and advertisements from us targeted on the basis of your search query history or on the basis of information received from third party partners, you are able to opt out of such targeting in the settings of the Application. See here for more detail.
The Service includes an internal messaging system which provides you the ability to send and receive messages to and from other users, and to receive marketing messages from us. You hereby agree that we may use the internal messaging system for the purpose of informing you regarding products or services, which may interest you.
Please note however that other CirclesX users are not allowed to use your contact details or our internal messaging account for commercial advertising purposes. If you have encountered any user generated advertising material, please inform us through the channels listed on the “About” menu in the Software or through the “Contact Us” page on the Site (link here). CirclesX does not accept any liability for any loss, damage, cost or expense that you may suffer or incur as a result of or in connection with any user’s advertising material.
It is clarified that we are not responsible for the content of said advertisements and the products delivered or services rendered thereby by third parties and you irrevocably and unconditionally agree that we shall not be held responsible or liable in connection thereof.
CirclesX considers information security to be a top priority. CirclesX implements systems, applications and procedures to secure your personal information, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. However, these measures are unable to provide absolute assurance. Therefore, although CirclesX takes great efforts to protect your personal information, CirclesX cannot guarantee and you cannot reasonably expect that CirclesX’s databases will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.
Last Modified: February 20, 2020