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.

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, tickets, subscriptions, and other features you choose to use;
• protect members and the Services, prevent fraud and abuse, investigate reports, enforce our rules, and comply with legal obligations;
• process payments, issue invoices, administer refunds and payouts, and provide customer support;
• send service, security, safety, and account notices, and send optional marketing only where permitted and subject to your choices; and
• measure and improve reliability, accessibility, performance, and the way Circlio works.

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.

Circlio uses precise live location to make nearby discovery work. You control whether your profile appears on the map and your discovery radius through Privacy settings. Turning off map visibility stops your profile from appearing on the map, although we may still process location where needed to provide a feature you actively use or to protect the Services.

We do not display your exact location to other members as a precise pin. Circlio snaps map coordinates to a privacy grid of roughly 1.1 km before showing them, so the map represents an area rather than your address. This protection reduces risk but is not a guarantee that someone cannot infer information from what you choose to share elsewhere.

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: Didit for identity verification; Razorpay, Apple, and Google for applicable payments; communications, cloud storage, security, and notification providers that process data on our behalf under contract.
• 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 may use cookieless analytics only when enabled. We do not use advertising trackers on the website by default.

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. In-app notifications are normally deleted after 30 days.

When you request account deletion, we revoke access and schedule direct account-data scrubbing 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 an export of data available through the Circlio privacy tools; 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, discovery radius, messaging permissions, online status, read receipts, story-view visibility, and notification preferences in the app. 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 use reasonable technical and organisational safeguards designed to protect personal data from unauthorised access, loss, misuse, alteration, and disclosure. No service can promise absolute security; please use a strong account credential, protect your device, and contact us promptly if you suspect unauthorised access.

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. 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.