The entities comprising Dreamplug Technologies Private Limited (DTPL), its subsidiaries, and affiliated companies (collectively referred to herein as We, Us, or Circle), place paramount importance on safeguarding the privacy and security of your (hereinafter referred to as You, Your, or User) personal information (Personal Data). Circle by CRED is a private access layer designed to restore connection and perspective. We prioritize the establishment and maintenance of Your trust. This privacy policy (Privacy Policy) outlines the methods and principles governing our collection, use, processing, and disclosure of Your Personal Data in connection with Your use of the Circle application (App) and services. By using Circle, You acknowledge that You have read, and understood, and agree to the processing of Your Personal Data in accordance with this Privacy Policy.
Collection of information
To maintain an exclusive and secure community, We collect specific information to authenticate Your identity, facilitate transactions, and enable real-time connections.
1. User Provided information
To provide You a secure onboarding experience, and to make sure You are a verified user within our high-trust ecosystem, We collect:
- Profile Data: Your Full Name, Age, and Gender.
- Contact Details: Your Phone Number and Email ID.
- Verification Status: CRED Coin balance to assess Your eligibility to access the platform.
- Device data: Information relating to the device used to access the App.
- Payment and Transaction Information: Information related to payments made on the App and in relation to the services received through the App.
To make live consultations work seamlessly, the App requires Your permission to access:
- Camera & Microphone: To enable live video and audio sessions with Circle Residents.
- Notification Permissions: To enable real-time updates, timely reminders for upcoming consultations.
- File Storage: To allow You to upload documents (like PDFs or images) for Residents' review and to facilitate secure file sharing.
2. Information generated through the use of Circle application
To maintain continuity and quality of service, to detect and prevent fraud, spam, abuse, security incidents, and other harmful activity, We process and store data generated during Your sessions:
- Media Recordings: Full audio and video recordings of Your live consultations, as available in Your chat history with the Residents.
- Documents Uploaded: Any documents shared by You with the Residents during the live consultation sessions.
- Communication Logs: Chat transcripts and automated AI-generated conversation summaries.
- Session Metadata & Logs: Technical details of your engagement, including session duration, timestamps, IP addresses and browser types to ensure service stability and security.
- Transaction & Payment Logs: Records of financial transactions, including payment status, billing details, transaction IDs, and history of purchased consultation subscriptions.
- Feedback & Quality Ratings: Any ratings, reviews, or qualitative feedback you provide regarding the Residents or the consultation experience for quality assurance and service improvement.
Utilization of information
We use the information We collect strictly to operate and improve the Circle experience:
- Facilitating Consultations: To connect You with the right Residents via secure, high-quality channels and to share the documents shared by you with the Residents.
- Quality Assurance: To review session recordings to maintain our high service standards and accurately resolve any disputes.
- Personalization: To tailor Your experience on the platform by using Your preferences and platform activity, personalise features of the app as well as to serve personalized advertisements that align with Your interests.
- Service Improvement: To enable Residents to evaluate their performance, address specific concerns, and continuously improve the quality of their professional services on the basis of your ratings and reviews.
- Data Analytics: To improve User experience, enhance performance, and accomplish desired results.
- Security: To continuously detect and prevent fraudulent activity on the platform.
Disclosure and sharing of data
We operate on a strict 'Privacy-First' principle. Below is how we may share your Personal Data.
1) Circle Residents
We segment Your information to completely protect Your identity while giving Residents the context they need to help You. Here is exactly what is, and is not, shared with the Residents You connect with:
- Name: Only Your First Name is shared with the Resident to personalize the session.
- Age and Gender: Your age and gender may be shared with the Resident when You initiate a chat request. This information is provided solely to offer basic context and help facilitate a more relevant and meaningful interaction.
- Contact Details (Phone Number & Email): NEVER shared. These remain solely with Circle and are never revealed to the Resident.
- File Uploads and Transcripts: Anything You share during the chat including File Uploads and Chat Transcripts is available to Your Resident. This provides them with the necessary context to give You relevant advice and ensures continuity of service for Your future sessions.
While engaging in live sessions or interacting with Residents, We strongly advise You to refrain from disclosing critical sensitive information such as your account passwords, PINs, financial credentials such as CVVs, Bank account number and other critical information that could lead to harm or misuse if disclosed. Sharing these specific credentials is at Your own risk and may lead to unauthorized account access or misuse.
2) Third-party service providers
We engage third-party service providers to handle complex infrastructure such as real-time audio/video streaming, cloud hosting, communications via SMS, WhatsApp, emails and payment processing. We utilize Artificial Intelligence (AI) tools to generate automated chat summaries. To enhance Your experience on the Circle App, We may also share Your specific data with our analytics partners. These service providers process data strictly on a need-to-know basis and are contractually obligated to safeguard Your information.
3) Legal, regulatory requirements
We may disclose information if required by law (including internal disciplinary committees), court order, or if We reasonably believe that such action is necessary to protect the physical safety of any person, or to prevent fraud and illegal activity.
Your rights & controls
You have full control over Your data. We support and encourage all Users to contact Us for questions, concerns, or suggestions relating to our privacy policy.
Under certain circumstances, You might be able to view or modify Your personal data online. If Your information is not accessible online, and You desire to procure a copy of specific information You provided to us, or if You become aware of inaccuracies in the data or wish to request its deletion, We encourage You to reach out to Us.
Before We give You any information or rectify any inaccuracies, We may ask You to validate Your identity and provide additional details to confirm Your identity and facilitate our response to Your request. We commit to reaching out to You within 72 hours of Your request and resolving it within 30 days.
Please note that upon a request for deletion, We may retain certain information for a reasonable period as necessary to fulfill the purposes outlined in this Policy or as mandated by legal and regulatory obligations.
For questions or concerns related to Your Personal Data, We can be contacted via the details on our Help & Support page on the Circle App or at queries@circlebycred.club.
Retention
Retention of Your Personal Data is only for the duration necessary for Us to fulfil the purposes mentioned in this privacy policy. Personal Data will be retained only for the duration necessary to fulfill the purposes laid out in this Privacy Policy, unless a longer retention period is necessitated by law or for legitimate business purposes directly related to or arising from Your use of the App.
Grievance redressal
In the event of any grievance pertaining to our privacy policy or practices involving the usage of data, the Grievance Redressal Officer may be contacted. For any concerns regarding Your experience with Circle App, You can reach out to our grievance redressal officer via our Help & Support page on the Circle App or at queries@circlebycred.club. If Your issue remains unresolved, you can escalate it to our grievance officer (Mr. Atul Patro) by clicking
here.
Security practices for storage
We are committed to preserving the integrity of Your Personal Data and maintaining its accuracy. We adopt reasonable physical, administrative, and technical safeguards to protect Your Personal Data from unauthorized access, use, and disclosure. More details regarding our security practices can be found
here. If You identify a potential security vulnerability in the App or website, please report it to Us responsibly. We request You to submit a detailed bug report, including steps required to reproduce the vulnerability, to Us at security@cred.club. We pledge our best efforts to investigate and rectify legitimate issues within a reasonable timeframe while requesting You not to disclose them publicly.
Dispute resolution and governing law
This policy is governed by the laws of India. Any dispute arising out of or related to Circle By CRED App shall be subject to the dispute resolution mechanism set out in the
Terms of Use of the Circle By CRED App.
Modifications to this policy
We reserve the right to amend this policy at our discretion. Continued use of the App following any changes constitutes acceptance of the modified Privacy Policy.