OnCircle AI - Privacy Policy

Last Updated: July 28, 2025

Your privacy is paramount to OnCircle AI. This Privacy Policy outlines the types of information we collect and process from and about you, how we use it, and how we protect it when you use our website and services (collectively, the “Services”).

By using the Services, you are agreeing to the practices described in this Policy. If you do not agree to these practices, please do not access or use the Services.

2.1 Information We Collect

When you access or otherwise use our Services, we may collect information from you. The types of information we collect depend on how you use our Services. Please note that we need certain types of information to provide the Services to you. If you do not provide us with such information, or if you ask us to delete that information, you may no longer be able to access or use certain Services. The information we collect may include data you directly provide to us, data we obtain automatically from your interactions with our Services, and data we obtain from other sources.

Information you provide directly to us:

You may provide us with information directly when you use the Services, communicate with us, register for an account, or subscribe to newsletters. This information may concern you and others and may include, but is not limited to:

  • Email address
  • User name (if applicable)
  • Payment information (e.g., through our secure payment processing vendors)
  • Your input and queries (e.g., chat communications, legal questions you submit to the AI)
  • Contents of communications with us (e.g., customer support inquiries)

You are not required to provide us with such information, but certain features of the Services may not be accessible or available without it.

Information we collect automatically:

We and our third-party vendors (which may include analytics companies such as Google Analytics) may use cookies, web beacons, and other tracking technologies to collect information about the computers or devices (including mobile devices) you use to access the Services. This information may include, but is not limited to:

  • Browser type
  • Operating system
  • Domain name
  • Access time
  • Referring or exit pages
  • Page views and navigation paths within our site
  • IP address
  • Unique device identifiers (e.g., IDFA or Android ID)
  • Version of our Services you’re using
  • Type of device that you use

We may also track when and how frequently you access or use the Services, including how you engage with or navigate our site. We use this information for analytics (to understand popular sections and user preferences) and to improve the Services.

Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies. If you disable cookies, you may be prevented from taking full advantage of the Services, as some functionalities may not work properly. For more information, you can visit https://www.allaboutcookies.org/.

We may collect general location information (such as general location inferred from an IP address) when you use the Services.

Information we collect from other sources:

We may also collect information about you from other parties, such as when you are referred to us by another user. We may also receive information about you from third-party social platforms if you interact with our social media profiles or connect to your account using a third-party service (e.g., Google or social media login). When you connect through a Third-Party Account, we collect and store information provided by that third party (e.g., your account ID) to facilitate your connection to the Services. Connecting via a Third-Party Account is optional, and you can revoke permissions through that third-party service.

2.2 How We Use the Information We Collect

We may use your information for any of the following purposes:

  • Provide and administer the Services: To deliver the AI legal insights and functionalities you request.
  • Personalize the Services: To tailor AI responses and content to your specific legal queries and interests.
  • Comunicare with you: Including informing you about features or aspects of the Services, or communicating about changes to our terms, conditions, or policies, and responding to your inquiries, comments, or feedback.
  • Analyze, maintain, improve, and customize the Services: Including to train and refine our artificial intelligence/machine learning models based on usage patterns and interactions (ensuring that sensitive personal identifying information is removed or de-identified where appropriate for training).
  • Develop new programs and services.
  • Detect and prevent fraud, criminal activity, or misuses of our Service: To ensure the security of our IT systems, architecture, and networks.
  • Comply with legal obligations and legal processes: To protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other parties, including to enforce our Terms of Service and any other agreements.
  • Carry out any other purpose for which the information was collected.

We may combine information that we collect from you through the Services with information that we obtain from other sources. We may also aggregate and/or de-identify information collected through the Services. We may use and disclose de-identified or aggregated data for any purpose, including without limitation for research and marketing purposes.

2.3 When We Disclose the Information We Collect

We may disclose your information in any of the following circumstances:

  • Affiliates: To our affiliates, meaning entities that control, are controlled by, or are under common control with OnCircle AI, consistent with this Policy.
  • Vendors and Service Providers: To employees, consultants, and other third-party vendors who need access to such information to carry out work or perform services on our behalf (e.g., data storage, payment processing, technology support, analytics, fraud prevention, marketing services).
  • Safety and Protection of OnCircle AI and Others: If we believe in good faith that doing so is necessary or appropriate to (i) protect or defend OnCircle AI or other parties, including to defend or enforce this Policy, our Terms of Service, or any other contractual arrangement; and/or (ii) protect the rights, property or personal safety of OnCircle AI, our agents and affiliates, our employees, users and/or the public.
  • Advertising and Analytics: We may disclose or make available some of your information with advertising and analytics partners to serve advertisements on our behalf across the internet and to provide analytics services. These entities may use cookies and tracking technologies to allow us to, among other things, track and analyze data, determine content popularity, and deliver targeted advertising. For more information, see the "Online Analytics and Tailored Advertising" section below.
  • Legal Requirements: If we believe in good faith that doing so is necessary or appropriate to comply with any law enforcement, legal, or regulatory process, such as to respond to a warrant, subpoena, court order, or other applicable laws and regulations.
  • Business Transfers: In connection with or during negotiations or closing of any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
  • Your User Content (Queries): While your direct queries are typically private conversations with the AI, any general insights or patterns derived from aggregated and de-identified data may be used to improve the service for all users. We do not make individual, identifiable legal queries publicly available.
  • Other Disclosures with Consent or at Your Direction: We may disclose your information to non-affiliated third parties based on your consent or at your direction.

2.4 Online Analytics and Tailored Advertising

Analytics:

We may use third-party web analytics services on the Services, such as those of Google Analytics. These vendors use technology to help us analyze how users use the Services. The information collected will be disclosed to or collected directly by these vendors, who use the information to evaluate your use of the Services. To prevent Google Analytics from using your information for web analytics, you may install the Google Analytics Opt-Out Browser Add-on.

Tailored Advertising:

We may allow third-party advertising networks to place cookies or other tracking technologies on your device to collect information about your use of the Services in order to (a) inform, optimize, and serve marketing content based on past visits to our website and other online services and (b) report how our marketing content impressions and interactions are related to visits to our online services.

If you are interested in more information about tailored advertising and how you can generally control cookies from being put on your computer to deliver tailored marketing, you may visit the Network Advertising Initiative’s (“NAI”) Consumer Opt-Out Link, the Digital Advertising Alliance’s (“DAA”) Consumer Opt-Out Link, and/or the European Interactive Digital Advertising Alliance to opt-out of receiving tailored advertising from companies that participate in those programs. To exercise choices about how Google personalizes Display Advertising or to customize Google Display Network ads, you can visit the Google Ads Settings page.

2.5 Your Choices and Rights

We offer you certain choices regarding the collection, use, and disclosure of information about you. Your local law may provide you with certain rights with respect to your information. Depending on your jurisdiction, you may request that we:

  • Access and Information: Provide you with information about the categories of personal information we collect or disclose about you, the sources, purposes, and recipients.
  • Access/Copy: Provide access to and/or a copy of certain information we hold about you.
  • Correction/Update: Update information which is out of date or incorrect.
  • Deletion: Delete certain information that we are holding about you. Please note that certain information may be exempt from such requests under applicable law (e.g., for legal compliance or service security). We may need certain information to provide the Services; if you ask us to delete it, you may no longer be able to use the Services.
  • Restriction: Restrict the way that we process and disclose certain information about you.
  • Data Portability: Transfer your information to a third-party provider of services.
  • Object/Opt-out: Prevent the processing of your information for direct-marketing purposes or for profiling in furtherance of decisions that produce legal or similarly significant effects.
  • Withdraw Consent: Revoke your consent for the processing of your information where consent was the basis for processing.

You may be able to designate an authorized agent to make requests on your behalf. We may take steps to verify your identity and the agent's authorization before processing such requests. You also have the right to not be discriminated against (as provided for in applicable law) for exercising your rights.

To exercise any of these rights, please contact us using the information in the "Contact Us" section below. To protect your privacy and security, we take reasonable steps to verify your identity and requests before granting them.

2.6 Regional Privacy Disclosures

Residents of the European Economic Area (EEA) and United Kingdom:

OnCircle AI is considered the "data controller" of the "personal data" (as defined under the General Data Protection Regulation - GDPR, and the UK GDPR) we handle under this Policy. This means OnCircle AI is responsible for deciding how to collect, use, and disclose personal data. Our legal grounds for processing your personal data are as follows:

  • Contractual Commitments: To fulfill our agreements with you and provide the Services you request.
  • With Your Consent: Where required by law, and in some other cases, we use, share, or disclose personal data on the basis of your explicit consent.
  • Legitimate Interests: In many cases, we use, share, or disclose personal data on the ground that it furthers our legitimate business interests (e.g., customer service, improving our business, providing security, preventing fraud, managing legal issues), provided these are not overridden by your interests or fundamental rights and freedoms.
  • Legal Compliance: To comply with our legal obligations.

In addition to the rights described in Section 2.5, you have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction.

Residents of California:

Under the California Consumer Privacy Act ("CCPA"), we collect and disclose categories of personal information for business or commercial purposes as described in Sections 2.1 and 2.3. These categories include identifiers, internet or other electronic network activity information, general geolocation data, and inferences drawn from the information we collect.

We do not knowingly "sell" or "share" the personal information of children under 16.

We do not respond to browser-initiated Do Not Track signals.

California residents can make requests about their personal information as described in Section 2.5.

2.7 Children’s Privacy

The Services are not designed for individuals under the age of 13. We do not knowingly collect personal information from children under 13. If we discover that an individual under 13 has provided us with "personal information," as defined in the Children's Online Privacy Protection Act ("COPPA"), we will take steps to close the account and delete the personal information to the extent required by COPPA. Our Terms of Service prohibit use by anyone under 13.

2.8 Security

OnCircle AI implements technical, administrative, and physical safeguards designed to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error-free. Therefore, we cannot guarantee the absolute security of your information or communications.

2.9 Data Retention

We keep your information for the time necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it, and your choices, after which time we may delete and/or aggregate it. We may also retain and use this information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

2.10 Consent to Transfer

Our services are global, and your information may be stored and processed in the United States or other countries outside the UK and EEA that may have data protection laws that differ from the laws in your country. Data may be accessible to law enforcement and national security authorities under certain circumstances in those jurisdictions. By using the Services, or providing us with any information, you consent to the collection, processing, maintenance, and transfer of such information to and within the United States and other applicable countries where privacy laws may not be as comprehensive as, or equivalent to, those in your country of residence.

2.11 Links to Third-Party Websites

The Services may contain links to third-party websites or services that are not operated by us. We are not responsible for the content or practices of those websites or services. The collection, use, and disclosure of your information by third parties will be subject to their respective privacy policies, and not this Policy. We urge you to read the privacy and security policies of these third parties before providing information to them.

2.12 Changes to this Policy

We reserve the right, at our sole discretion, to change or modify portions of this Policy at any time. If we do this, we will post the changes on this page and will indicate at the top of this page the date these terms were last revised. Any such changes will become effective no earlier than 14 days after they are posted, except that changes addressing new functions of the Services or changes made for legal reasons will be effective immediately. Your continued use of the Services after the date any such changes become effective constitutes your acceptance of the new Policy.

2.13 Contact Us

If you have any questions about our Privacy Policy or information practices, please contact us at [Your Support Email Address/Link to Contact Form].