Privacy Policy

ADHUNIK LABS PRIVATE LIMITED (“Circlio”, “we”, “us”, or “our”) operates the Circlio website, mobile app, and related services. We are responsible for the personal data we process through those Services.

This policy explains how we handle digital personal data under applicable Indian law, including the Digital Personal Data Protection Act, 2023 and rules made under it. It should be read with our Terms & Conditions and Community Guidelines.

In short: we do not sell your data, we do not show advertising, and we do not use advertising identifiers.

We collect only the categories of data needed to provide, protect, and improve Circlio. The information we collect depends on how you use the Services.

We receive most information directly from you, from your device when you grant permission, from your activity in Circlio, and from service providers that process a feature you choose to use.

We use your personal data to:

• create and secure your account, authenticate you, and complete identity verification;
• show relevant people, circles, and events nearby; enable messages, RSVPs, and other features you choose to use;
• protect members and the Services: check the text you post or send for content that breaks our rules, prevent fraud and abuse, investigate reports, enforce our rules, and comply with legal obligations;
• provide customer support and, if paid features launch, process payments, issue invoices and administer refunds;
• send service, security, safety, and account notices (for example your sign-up code and password-reset emails), and send optional marketing only where permitted and subject to your choices; and
• measure and improve reliability, accessibility, performance, and the way Circlio works.

Automated checks. Text you post or send, including comments, messages, profile bios, and event and circle descriptions, is checked automatically for content that breaks our Community Guidelines. Some of these checks are run by a third-party AI moderation service (see below). Content the system judges to be clearly harmful may be hidden while our team reviews it. We do not use these checks for advertising.

We seek clear, specific consent when required. Where Indian law permits processing without consent for a specified legitimate use or where processing is required by law, we may rely on that legal basis. You can withdraw consent through the relevant app control or by contacting us, although this may prevent us from providing the affected feature.

The Circlio app asks your phone for the permissions below. You can refuse or change any of them in your phone settings; the features that need them will then not work.

We do not use your phone’s advertising ID, contacts, microphone, or SMS messages.

Circlio uses your device location to make nearby discovery work, and only while you are using the app — we do not track your location in the background. You control your discovery radius through Privacy settings, and you can turn off “Auto-update my location” and set your area by hand.

You are not shown on the map unless you put yourself there. Being discoverable in Circlio does not place a pin anywhere. To appear on the Live Map you must tap “Go live” and agree each time. Before you agree we tell you exactly what will be shared (your photo, name and approximate area), with whom (members near you who are also looking at the map), and for how long. You can decline, and you can stop sharing at any moment from the map.

Going live always ends by itself. Each time you go live you are visible for a limited window only — currently about four hours, and never more than twenty-four. When the window ends, your pin disappears automatically and you are no longer on the map. There is no setting that keeps you permanently visible, and we never extend a window for you or re-enable it on your behalf. If you want to appear again, you tap “Go live” again.

While you are live, members nearby can see your photo, name, shared interests and your approximate area for as long as the window lasts. When you are not live, none of that appears on the map. Separately, the map may show anonymous counts for an area — for example “34 people” for a neighbourhood. Those counts contain no names, photos or individual positions, they are drawn at the centre of a fixed grid square rather than at anyone’s actual position, and we do not show a count for an area with fewer than three people in it, so a count can never identify one person.

“Show me on the map” in Privacy settings remains the master switch. With it off you cannot go live at all, and you are excluded from the map, the area counts and people discovery entirely. Members you have blocked never see you on the map, and you never see them, in either direction. We may still process location where needed to provide a feature you actively use or to protect the Services. The separate exception is a location you choose to send in a chat, which the people in that chat can see.

We do not sell personal data. We share it only as needed for the Services or where required or permitted by law, including:

• With other members, hosts, organisers, or attendees: information you make visible through your profile, circles, events, messages, RSVPs, and privacy settings.
• With service providers that process data on our behalf, listed below.
• For legal and safety reasons: where reasonably necessary to comply with law, respond to valid legal process, protect people from harm, investigate fraud or abuse, or enforce our terms.
• During a corporate transaction: if Circlio is involved in a merger, financing, acquisition, restructuring, or sale of assets, subject to appropriate safeguards and applicable law.

Our website uses analytics (PostHog) to understand visits: the pages and sections people view, clicks, scroll depth, approximate country and city, and device type. By default this runs without cookies. If you choose Accept in the cookie banner, we set one first-party analytics cookie so we can recognise you when you return; if you choose Decline, or make no choice, no analytics cookie is set and your visits are counted anonymously. You can change your choice at any time with the Cookie settings link at the bottom of every page. The website does not record sessions, identify you by name or email, or link your website visit to your app account. We do not use advertising trackers on the website.

We keep personal data only for as long as needed for the purpose described in this policy, including account operation, safety, dispute handling, legal compliance, and fraud prevention.

Deleting your account. You can delete your account in the app under Settings → Privacy → Delete account, or by emailing info@circlio.social. Full steps are on our account deletion page. When you request deletion, we sign you out, close your account, and erase or de-identify your direct account data within 30 days. Some limited records may be retained for up to 180 additional days where necessary for security, legal, tax, fraud-prevention, audit, or dispute purposes. Content that has been shared with a circle or event may remain in de-identified or archived form where necessary to preserve the record of that space or meet a legal obligation.

Deletion does not require us to remove information that another member independently saved or shared outside Circlio, nor information we must retain by law.

Subject to applicable law, you can ask us to:

• confirm whether we process your personal data and provide a summary of it;
• correct inaccurate or incomplete data;
• erase personal data that is no longer needed or where you withdraw consent, subject to lawful retention requirements;
• withdraw consent for a specific use;
• receive a copy of your data on request by emailing us; and
• nominate another person to exercise your rights if you die or become incapacitated, where applicable law provides that right.

You can change map visibility, location auto-update, discovery radius, messaging permissions, online status, read receipts, story-view visibility, and notification preferences in the app. The app does not yet have a switch for product analytics; if you want us to stop, email us and we will act on it. To make a privacy request or raise a complaint, email info@circlio.social. We may need to verify your identity before acting on a request.

We aim to acknowledge requests within 24 hours and to resolve them within 15 days. If you are not satisfied with our response, you may complain to the Data Protection Board of India once you have used our grievance process.

We use reasonable technical and organisational safeguards designed to protect personal data from unauthorised access, loss, misuse, alteration, and disclosure, including encryption of connections and of sensitive stored fields. No service can promise absolute security; please use a strong account credential, protect your device, and contact us promptly if you suspect unauthorised access. If a personal data breach affects you, we will tell you and the authorities as the law requires.

Our service providers may process data in India or other locations where they operate. When data is processed outside India, we take steps designed to ensure the transfer is permitted by applicable law and protected by appropriate contractual or other safeguards.

Circlio is for adults aged 18 and over. You must give your date of birth when you sign up, and we verify identity with a government ID. We do not knowingly allow children to create accounts. If you believe a child has provided personal data to us, contact us and we will take appropriate action.

We may update this policy when our Services, processing practices, or legal obligations change. We will post the updated policy here, revise the date above, and provide additional notice for material changes where required.