{"id":4813,"date":"2026-09-24T09:49:48","date_gmt":"2026-09-24T09:49:48","guid":{"rendered":"https:\/\/publiccircles.com\/privacy-policy\/"},"modified":"2026-09-24T09:49:48","modified_gmt":"2026-09-24T09:49:48","slug":"privacy-policy","status":"publish","type":"page","link":"https:\/\/publiccircles.com\/en\/privacy-policy\/","title":{"rendered":"Privacy Policy"},"content":{"rendered":"<div class=\"wp-block-group alignfull pc-email-wrap is-layout-flow wp-block-group-is-layout-flow\">\n<div class=\"wp-block-group pc-email is-layout-flow wp-container-core-group-is-layout-ad7c68f1 wp-block-group-is-layout-flow\">\n<div class=\"wp-block-group legal-page is-layout-constrained wp-container-core-group-is-layout-ee2332cf wp-block-group-is-layout-constrained\">\n\n\n<div class=\"breadcrumb\"><a href=\"\/en\/\">Home<\/a> <span class=\"breadcrumb-sep\">&rsaquo;<\/span> <span>Privacy Policy<\/span><\/div>\n\n\n<h1 class=\"wp-block-heading\">Privacy Policy<\/h1>\n<p class=\"legal-meta wp-block-paragraph\">Public Circles Inc. &middot; Effective Date: August 17, 2026<\/p>\n\n<h2 class=\"wp-block-heading\">1. Introduction and Scope<\/h2>\n<p class=\"wp-block-paragraph\">Public Circles Inc., a corporation incorporated under the laws of Canada, together with its affiliates and subsidiaries (&#8220;Public Circles,&#8221; &#8220;we,&#8221; &#8220;us,&#8221; or &#8220;our&#8221;), respects the privacy of individuals who interact with us. This Privacy Policy (this &#8220;Policy&#8221;) explains how we collect, use, disclose, and safeguard personal information in connection with: (a) our website at www.publiccircles.com; and (b) our email and SMS marketing platform and related services (the &#8220;Services&#8221;).<\/p>\n<p class=\"wp-block-paragraph\">This Policy applies to personal information we handle as an organization in our own right (for example, information about our Clients and website visitors), and describes, at a general level, how we handle personal information we process on behalf of our Clients as part of providing the Services.<\/p>\n<p class=\"wp-block-paragraph\">This Policy is incorporated by reference into, and should be read together with, Public Circles&#8217; Terms and Conditions of Service (the &#8220;Terms&#8221;). A current copy of the Terms is available at www.publiccircles.com. In the event of a conflict between this Policy and the Terms with respect to the processing of personal information, this Policy will govern.<\/p>\n\n<h2 class=\"wp-block-heading\">2. Who This Policy Applies To<\/h2>\n<p class=\"wp-block-paragraph\">This Policy applies to several categories of individuals, whose personal information we handle in different ways and, in some cases, in different capacities:<\/p>\n<ul class=\"wp-block-list\"><li><strong>Clients and Users<\/strong> &mdash; businesses and individuals who register for and use the Services. We collect this information directly and act as the organization responsible for it.<\/li><li><strong>End Recipients<\/strong> &mdash; individuals whose contact information a Client uploads to, or collects through, the Services in order to send them communications. With respect to End Recipient Contact Data, Public Circles generally processes this information as a service provider on behalf of the Client, in accordance with that Client&#8217;s instructions and its own privacy notices.<\/li><li><strong>Website visitors<\/strong> &mdash; individuals who browse www.publiccircles.com, whether or not they become Clients.<\/li><\/ul>\n<p class=\"wp-block-paragraph\">If you are an End Recipient and have questions about why you received a communication or how your information is being used, you should first contact the business that sent you that communication (the Client), whose own privacy policy will generally apply. You may also contact us using the details in Section 12, and we will direct your request appropriately.<\/p>\n\n<h2 class=\"wp-block-heading\">3. Personal Information We Collect<\/h2>\n<p class=\"wp-block-paragraph\">We collect the following general categories of personal information:<\/p>\n<figure class=\"wp-block-table\"><table><thead><tr><th>Category<\/th><th>Examples<\/th><th>Relates To<\/th><\/tr><\/thead><tbody>\n<tr><td>Client account data<\/td><td>Name, business name, email address, phone number, billing address, payment details, login credentials<\/td><td>Clients and Users<\/td><\/tr>\n<tr><td>Contact Data (uploaded by Clients)<\/td><td>Names, email addresses, phone numbers, and engagement history of individuals a Client sends communications to<\/td><td>End Recipients<\/td><\/tr>\n<tr><td>Content Data<\/td><td>Campaign content, templates, and creative assets a Client creates or uploads<\/td><td>Clients<\/td><\/tr>\n<tr><td>Usage and device data<\/td><td>IP address, browser type, device identifiers, pages visited, log data, cookies<\/td><td>Website visitors, Clients, Users<\/td><\/tr>\n<tr><td>Support communications<\/td><td>Correspondence, support tickets, and call\/chat records<\/td><td>Clients, Users<\/td><\/tr>\n<tr><td>Engagement data<\/td><td>Email opens, link clicks, SMS delivery status, bounces, unsubscribes<\/td><td>End Recipients<\/td><\/tr>\n<\/tbody><\/table><\/figure>\n\n<h2 class=\"wp-block-heading\">4. How We Use Personal Information<\/h2>\n<p class=\"wp-block-paragraph\">We use personal information for the following purposes:<\/p>\n<ul class=\"wp-block-list\"><li>to create and administer Client accounts and provide the Services, including sending, tracking, and reporting on Clients&#8217; email and SMS campaigns;<\/li><li>to process payments and manage billing, including Wallet balances described in the Terms;<\/li><li>to provide customer support and respond to inquiries;<\/li><li>to monitor, secure, and improve the Services, including deliverability optimization, fraud prevention, and troubleshooting;<\/li><li>to communicate with Clients and Users about their accounts, updates to the Services, and, where consented to, promotional communications about Public Circles;<\/li><li>to operate and improve our website, including through analytics and cookies as described in Section 7; and<\/li><li>to comply with Applicable Law, respond to legal process, and enforce our Terms.<\/li><\/ul>\n<p class=\"wp-block-paragraph\">Where we process End Recipient Contact Data on behalf of a Client, we do so to enable that Client to send, deliver, and measure the performance of its own communications, in accordance with the Client&#8217;s instructions and the Terms, and not for our own independent marketing purposes except as described in Section 5.<\/p>\n\n<h2 class=\"wp-block-heading\">5. How We Share Personal Information<\/h2>\n<h3 class=\"wp-block-heading\">5.1 Service Providers<\/h3>\n<p class=\"wp-block-paragraph\">We engage third-party service providers to help us operate the Services and our business. These providers may access or process personal information solely to perform services on our behalf, subject to confidentiality and data protection obligations. General categories of service provider are set out below; this list mirrors, and should be read together with, Section 7.3 of the Terms.<\/p>\n<figure class=\"wp-block-table\"><table><thead><tr><th>Category of Service Provider<\/th><th>Purpose<\/th><th>General Location<\/th><\/tr><\/thead><tbody>\n<tr><td>Cloud hosting &amp; infrastructure<\/td><td>Servers, storage, databases, backups, and content delivery for the Services<\/td><td>United States \/ Canada<\/td><\/tr>\n<tr><td>Email &amp; SMS deliverability \/ gateway providers<\/td><td>Transmission of email and SMS messages on behalf of Clients, including bounce, spam-complaint, and delivery-status monitoring<\/td><td>Canada \/ United States<\/td><\/tr>\n<tr><td>Payment processors<\/td><td>Processing of subscription and usage-based fees charged to Clients<\/td><td>Canada \/ United States<\/td><\/tr>\n<tr><td>Analytics &amp; product usage providers<\/td><td>Measurement of platform performance, feature usage, and Service improvement<\/td><td>United States<\/td><\/tr>\n<tr><td>Customer support &amp; ticketing tools<\/td><td>Management of support requests and correspondence with Clients<\/td><td>Canada \/ United States<\/td><\/tr>\n<tr><td>Fraud prevention &amp; security providers<\/td><td>Detection of fraudulent, abusive, or malicious use of the Services<\/td><td>United States<\/td><\/tr>\n<tr><td>AI\/ML and content-assist providers<\/td><td>Optional features such as subject-line suggestions, send-time optimization, and content generation<\/td><td>United States<\/td><\/tr>\n<tr><td>Professional advisors<\/td><td>Legal, accounting, insurance, and audit services<\/td><td>Canada<\/td><\/tr>\n<\/tbody><\/table><\/figure>\n<h3 class=\"wp-block-heading\">5.2 Aggregated and De-Identified Data<\/h3>\n<p class=\"wp-block-paragraph\">We may create and use aggregated or de-identified data, derived from personal information but which does not identify any individual, for purposes such as benchmarking, product development, industry research, and our own marketing, as further described in Section 7.4 of the Terms.<\/p>\n<h3 class=\"wp-block-heading\">5.3 Legal and Corporate Transactions<\/h3>\n<p class=\"wp-block-paragraph\">We may disclose personal information where required by law, regulation, court order, or governmental request, or as part of a merger, acquisition, financing, reorganization, or sale of assets, in each case consistent with Sections 7.6 through 7.9 of the Terms.<\/p>\n<h3 class=\"wp-block-heading\">5.4 No Sale of End Recipient Data<\/h3>\n<p class=\"wp-block-paragraph\">We do not sell End Recipient Contact Data, and we do not disclose it to third parties for those third parties&#8217; own independent marketing purposes, except with consent or as otherwise described in this Policy and the Terms.<\/p>\n\n<h2 class=\"wp-block-heading\">6. Cross-Border Transfers<\/h2>\n<p class=\"wp-block-paragraph\">Public Circles is based in Canada, and the Services are available globally. Personal information we collect may be stored and processed in Canada, the United States, or other jurisdictions where we or our service providers maintain facilities. As a result, personal information may become subject to the laws of those jurisdictions, including lawful access requests by foreign governmental authorities. By using the Services or our website, you acknowledge this cross-border processing, to the extent permitted by Applicable Law.<\/p>\n\n<h2 class=\"wp-block-heading\">7. Cookies and Tracking Technologies<\/h2>\n<p class=\"wp-block-paragraph\">Our website and the Services use cookies and similar tracking technologies to operate core functionality, remember preferences, measure site and campaign performance, and, where applicable, support advertising. You can control cookies through your browser settings; disabling certain cookies may affect the functionality of our website or the Services. Where required by Applicable Law, we will request your consent before placing non-essential cookies.<\/p>\n\n<h2 class=\"wp-block-heading\">8. Data Retention<\/h2>\n<p class=\"wp-block-paragraph\">We retain personal information for as long as necessary to provide the Services, comply with our legal obligations, resolve disputes, and enforce our agreements. Client Data, including End Recipient Contact Data, is retained in accordance with Section 7.10 of the Terms and deleted or returned following termination of a Client&#8217;s account within the timeframe described there, subject to legitimate backup, archival, and legal retention requirements.<\/p>\n\n<h2 class=\"wp-block-heading\">9. Your Privacy Rights<\/h2>\n<p class=\"wp-block-paragraph\">Subject to Applicable Law and certain exceptions, you may have the right to: (a) request access to the personal information we hold about you; (b) request correction of inaccurate or incomplete information; (c) request deletion of your personal information; (d) withdraw consent to certain processing, where processing is based on consent; and (e) object to or request restriction of certain processing.<\/p>\n<p class=\"wp-block-paragraph\">To exercise these rights, please contact us using the details in Section 12. We may need to verify your identity before responding, and some requests may be limited where we are required to retain information by Applicable Law or where the information is being processed by us as a service provider on behalf of a Client, in which case we will direct you to that Client where appropriate.<\/p>\n<p class=\"wp-block-paragraph\">If you are an End Recipient and no longer wish to receive communications from a particular Client, the most effective step is to use the unsubscribe mechanism included in that Client&#8217;s communication, which the Terms require every Client to provide.<\/p>\n\n<h2 class=\"wp-block-heading\">10. Marketing Communications and CASL<\/h2>\n<p class=\"wp-block-paragraph\">Where we send commercial electronic messages to Clients or Users about our own products and services, we do so in accordance with Canada&#8217;s Anti-Spam Legislation and comparable Applicable Law, including obtaining consent where required and providing a functional unsubscribe mechanism in each message. You may withdraw consent to receive marketing communications from us at any time by using the unsubscribe link in our messages or by contacting us using the details in Section 12.<\/p>\n\n<h2 class=\"wp-block-heading\">11. Security<\/h2>\n<p class=\"wp-block-paragraph\">We maintain administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, disclosure, alteration, or destruction. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.<\/p>\n\n<h2 class=\"wp-block-heading\">12. Contact Us<\/h2>\n<p class=\"wp-block-paragraph\">Questions, concerns, or requests regarding this Policy or our privacy practices, including access, correction, or deletion requests, may be directed to Public Circles Inc. through the contact information published at www.publiccircles.com, or in writing to our privacy contact identified on that page.<\/p>\n\n<h2 class=\"wp-block-heading\">13. Children&#8217;s Privacy<\/h2>\n<p class=\"wp-block-paragraph\">The Services are not directed to, and we do not knowingly collect personal information from, individuals under the age of majority in their jurisdiction of residence. If we become aware that we have collected personal information from a child without appropriate consent, we will take steps to delete that information.<\/p>\n\n<h2 class=\"wp-block-heading\">14. Changes to this Policy<\/h2>\n<p class=\"wp-block-paragraph\">We may update this Policy from time to time to reflect changes in our practices or Applicable Law. We will post the updated Policy at www.publiccircles.com with a revised effective date, and, where changes are material, will provide additional notice as described in Section 18 of the Terms. Your continued use of the Services or our website after the effective date of an update constitutes acceptance of the revised Policy.<\/p>\n\n<h2 class=\"wp-block-heading\">15. Relationship to the Terms and Conditions<\/h2>\n<p class=\"wp-block-paragraph\">This Policy forms part of, and is incorporated by reference into, Public Circles&#8217; Terms and Conditions of Service. A current copy of the Terms is available at www.publiccircles.com. Capitalized terms used but not defined in this Policy have the meanings given to them in the Terms.<\/p>\n\n<\/div>\n<\/div>\n<\/div>","protected":false},"excerpt":{"rendered":"<p>Home &rsaquo; Privacy Policy Privacy Policy Public Circles Inc. &middot; Effective Date: August 17, 2026 1. Introduction and Scope Public Circles Inc., a corporation incorporated under the laws of Canada, together with its affiliates and subsidiaries (&#8220;Public Circles,&#8221; &#8220;we,&#8221; &#8220;us,&#8221; or &#8220;our&#8221;), respects the privacy of individuals who interact with us. This Privacy Policy (this [&hellip;]<\/p>\n","protected":false},"author":6,"featured_media":0,"parent":0,"menu_order":0,"comment_status":"closed","ping_status":"closed","template":"","meta":{"_acf_changed":false,"footnotes":""},"class_list":["post-4813","page","type-page","status-publish","hentry"],"acf":[],"_links":{"self":[{"href":"https:\/\/publiccircles.com\/en\/wp-json\/wp\/v2\/pages\/4813","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/publiccircles.com\/en\/wp-json\/wp\/v2\/pages"}],"about":[{"href":"https:\/\/publiccircles.com\/en\/wp-json\/wp\/v2\/types\/page"}],"author":[{"embeddable":true,"href":"https:\/\/publiccircles.com\/en\/wp-json\/wp\/v2\/users\/6"}],"replies":[{"embeddable":true,"href":"https:\/\/publiccircles.com\/en\/wp-json\/wp\/v2\/comments?post=4813"}],"version-history":[{"count":0,"href":"https:\/\/publiccircles.com\/en\/wp-json\/wp\/v2\/pages\/4813\/revisions"}],"wp:attachment":[{"href":"https:\/\/publiccircles.com\/en\/wp-json\/wp\/v2\/media?parent=4813"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}