Global Privacy Policy
Effective Date: December 1, 2025 Last Updated: December 1, 2025
1. Introduction
Welcome to CloseCircle. We respect your privacy and are committed to protecting your personal data. This Global Privacy Policy explains how we collect, use, share, and protect your information when you use our live streaming platform and services (the "Service").
This policy applies to all users of CloseCircle globally. While we operate as a unified platform, the specific legal entity responsible for your data depends on your location to ensure compliance with local laws.
1.1 Data Controller
The specific entity acting as the Data Controller for your personal information is:
- For users in the EEA, UK, and Switzerland: CloseCircle s.r.o. Na Malé Šárce 801, Nebušice, 164 00 Praha, Czech Republic EU Tax ID: CZ23109777
- For users in the United States and Rest of World: CloseCircle US Inc. 131 Continental Dr, Suite 305, Newark, DE 19713, United States
For all privacy-related inquiries, you can contact our central Data Protection Officer (DPO) team at: privacy@closecircle.io
2. Information We Collect
We practice data minimization, collecting only the information necessary to provide our Service and comply with financial regulations.
2.1 Information You Provide Directly
- Account Data: Name, email address, username, encrypted password, and profile image.
- Creator Verification Data: If you apply to be a Creator, we may collect government ID or other verification documents for KYC (Know Your Customer) compliance.
- Financial Data:
- For Buyers: Transaction history and billing address. Note: We do not store full credit card numbers; these are processed directly by our payment processor (Stripe).
- For Creators: Banking details and tax identification numbers (e.g., SSN, VAT ID) required to process payouts via Tipalti.
- Communications: Content of messages sent to support or via platform chat features.
2.2 Information Collected Automatically
- Technical Data: IP address, browser type, device model, operating system, and time zone setting.
- Usage Data: Login timestamps, pages viewed, session duration, and interaction events (e.g., "Join Stream" clicks).
3. How We Use Your Information
We process your data for specific purposes. For users in the EEA/UK, we rely on the following legal bases under GDPR:
| Purpose of Processing | Data Categories | Legal Basis (GDPR) |
|---|---|---|
| Service Delivery: Authentication, hosting live streams, processing ticket purchases. | Account, Payment, Technical | Contract Performance (Art. 6(1)(b)) |
| Creator Payouts: Calculating and sending earnings. | Creator Data, Financial | Contract Performance |
| Tax & Compliance: VAT/Sales tax calculation (via Anrok) and fraud prevention. | Financial, Transaction | Legal Obligation (Art. 6(1)(c)) |
| Analytics: Improving platform performance and user experience. | Usage, Technical | Consent (Art. 6(1)(a)) |
| Security: Detecting bots, preventing account takeovers, and debugging. | Technical, Usage | Legitimate Interest (Art. 6(1)(f)) |
4. Cookies and Tracking Technologies
We use cookies to ensure our platform works securely and to analyze performance.
4.1 Strictly Necessary Cookies
These are essential for the website to function (e.g., keeping you logged in, CSRF security tokens). You cannot opt out of these.
4.2 Analytics Cookies (Google Analytics)
We use Google Analytics 4 (GA4) to understand aggregate usage patterns.
- Data Collected: Anonymized IP addresses, page views, and device type.
- Consent (EEA/UK): We only activate these cookies if you click "Accept" on our Cookie Banner.
- Opt-Out: You may opt out globally using the Google Analytics Opt-out Browser Add-on.
4.3 "Do Not Track" Signals (CalOPPA Disclosure)
Some web browsers transmit "Do Not Track" (DNT) signals. Because there is no uniform industry standard for how to interpret these signals, CloseCircle does not currently respond to DNT signals.
5. Data Sharing and Service Providers
We do not sell your personal data to data brokers. We share data only with the following categories of third-party service providers, who are contractually bound to protect your data:
- Payment & Payouts: Stripe (payments) and Tipalti (creator payouts).
- Tax Compliance: Anrok (automated global sales tax/VAT calculation).
- Infrastructure: GetStream (video/chat infrastructure) and AWS/Google Cloud (hosting).
- Analytics: Google Analytics (usage metrics).
- Legal Obligations: We may disclose data to law enforcement if compelled by a valid court order, subpoena, or to prevent imminent physical harm or financial fraud.
6. International Data Transfers
Your personal data may be transferred to, and processed in, the United States, where our central servers and many of our service providers are located.
For EEA/UK Users: When transferring data to the US, we ensure protection via:
- EU-U.S. Data Privacy Framework: For vendors certified under the framework (e.g., Google, Stripe).
- Standard Contractual Clauses (SCCs): For all other vendors, ensuring they meet European data protection standards.
7. Data Retention
We retain personal data only as long as necessary for the purposes set out in this policy:
- Active Accounts: Data is retained while your account is active.
- Financial Records: Retained for 7 years to comply with tax and accounting laws (e.g., IRS, EU VAT directives).
- Technical Logs: Retained for 12 months for security auditing.
- Deletion: If you request account deletion, we permanently erase your profile data within 30 days, retaining only the mandatory financial records mentioned above.
8. Your Privacy Rights
8.1 Global Rights (Available to All Users)
- Access: Request a copy of the data we hold about you.
- Correction: Update inaccurate information in your settings.
- Deletion: Request the permanent removal of your account.
8.2 Rights for EEA/UK Users (GDPR)
- Withdraw Consent: You may withdraw consent for optional cookies/marketing at any time.
- Data Portability: Request your data in a structured, machine-readable format.
- Lodge a Complaint: You have the right to complain to the Czech Data Protection Authority (Úřad pro ochranu osobních údajů) at posta@uoou.cz.
8.3 Rights for California Residents (CCPA/CPRA)
- Right to Know: You may request the specific categories of personal information we collected in the past 12 months.
- Right to Non-Discrimination: We will not deny services or charge different prices for exercising your rights.
- "Do Not Sell or Share" Disclosure: CloseCircle does not sell your personal data for monetary value. However, our use of Google Analytics may constitute "Sharing" of data for cross-context behavioral analytics under California law. You may opt out of this by declining non-essential cookies in your settings or using the Global Privacy Control (GPC) signal.
To exercise any of these rights: Email privacy@closecircle.io. We will verify your identity before processing the request.
9. Children's Privacy (15+ Policy)
Minimum Age: CloseCircle is strictly for users aged 15 and older.
Parental Consent (Ages 15–16 in Europe): If you are aged 15, but reside in a country where the digital age of consent is 16 (e.g., Germany, Ireland), you represent that you have obtained your parent or guardian's permission to use the Service.
If we become aware that we have collected data from a child under 15, we will delete that information immediately. If you believe a child under 15 has provided us with data, please contact us at privacy@closecircle.io.
10. Changes to This Policy
We may update this Privacy Policy periodically. If we make material changes, we will notify you via email or a prominent notice on the platform prior to the change becoming effective.
11. Contact Information
If you have questions about this policy or our privacy practices, please contact us:
- Email: privacy@closecircle.io
- EU Mailing Address: CloseCircle s.r.o., Na Malé Šárce 801, Nebušice, 164 00 Praha, Czech Republic
- US Mailing Address: CloseCircle US Inc., 131 Continental Dr, Suite 305, Newark, DE 19713, United States