Privacy Policy
Last updated: October 22, 2026
1. Introduction
The privacy of our users and of the people whose data they share is of utmost importance to us. This platform (the "Platform" or "Circli") is operated by Circli Servicios Tech S.A.S., a company duly registered with the Public Registry of the Province of Mendoza under File N° eSAS-000542, CUIT 30-71944030-0, with registered office in the City of Mendoza, Argentina. This Privacy Policy describes what personal data we process, for what purposes, with whom we share it, and what rights you have over your information, in accordance with Argentine Law 25,326 on Personal Data Protection and other applicable legislation. By using the Platform, you accept the practices described in this policy.
2. Roles and responsibilities
Circli may act as either a controller or a processor of your personal data, depending on the context: (a) When you create an account directly at circli.app, browse the site, or contact us, Circli is the controller of that data. (b) When you use Circli as part of an event organized by a third party (such as a fair, congress or conference), the event organizer is the controller of the data generated within that event, and Circli acts as a processor on behalf of the organizer. In these cases: • The organizer defines the purposes of the processing within the event. • Circli processes the data following the organizer's documented instructions, under a Data Processing Agreement signed with each organizer. • To exercise your rights regarding event-generated data, your first point of contact is the event organizer. Circli cooperates with the organizer to respond to your request. • The organizer maintains its own privacy notice describing the event-specific uses. We recommend you read it. (c) For aggregated and anonymous technical data (usage metrics, fraud prevention), Circli maintains its own responsibility for limited purposes related to operating the Platform securely.
3. Limitation of liability for organizer's uses
When Circli acts as a processor on behalf of an event organizer, Circli is not liable for: • The organizer's use of the data outside the Circli Platform (e.g., exports, post-event communications, organizer's own integrations). • Obtaining the data subject's consent for purposes the organizer defines on its own. • Leaks, unauthorized access or improper uses of the data occurring in the organizer's infrastructure, devices or processes, or in those of third parties contracted by the organizer. • Compliance with laws applicable to the organizer in its own jurisdiction and regarding its own uses. • Registering its database with the National Registry of Personal Data Bases (section 21, Law 25,326) and publishing its own privacy policy and terms towards its attendees or members. As the controller, those obligations are the organizer's; Circli can walk them through the filing, but does not do it for them nor answer for its omission. This limitation does not apply when the incident occurs within Circli's infrastructure or results from Circli's failure to follow the organizer's documented instructions.
4. Personal data we collect
We collect only the personal data necessary to provide the service, in the following categories: • Account data: email, name or alias, and optionally a mobile phone number. • Event data (when you use Circli as part of an event): name, company, professional role or category, optional profile photo, connections generated with other attendees, and activity records within the event. • Contact data voluntarily shared by you: name and phone number of third parties you choose to add to your circle on the Platform. • Community participation data (Circli Networks): your network profile, the answers you give in the membership application form, what you post in the feed and in comments, and — if the network runs courses — your progress, your quiz answers and their result, your private study notes, any certificates you earn and the participation points you accumulate. • Membership payment data: when a network charges for membership, the payment is processed by Mercado Pago. Your card or bank account details are received and stored by Mercado Pago, not by Circli. On our side we only keep the record of the transaction: the payment reference, the amounts and the date. • Browser notification data: if you turn on web notifications, we store the delivery address issued by your browser, the two keys used to encrypt the notification body, the device type and a truncated version of your user-agent so we can diagnose a delivery failure. We delete that address when you turn notifications off from your profile, when your browser's push service tells us it is no longer valid, and when your account is deleted. • Approximate location data, only in an event's game activity: when you scan an exhibitor stand's code we may record the location reported by your device and behavioural signals about the scan. This is used exclusively to detect cheating in the game; we do not build any profile of you from it, nor use it for advertising. • Technical data: IP address and user-agent. In consent records and agreement acceptances we always store them as a salted hash, never in plaintext. In security, administrative-access audit and fraud-prevention logs we may keep them in the clear for as long as that purpose requires. In the measurement of our own website we store the country inferred from the IP and the user-agent, plus an identifier derived from both that does not allow the original IP to be recovered. • Cookies and similar technologies: see dedicated section below.
5. Purpose and use of data
We use the personal data collected for the following purposes: • Service provision: enabling you to create your circle, manage your contacts and participate in events using the Platform. • Operating events for organizers who contract the Platform, always in accordance with the organizer's documented instructions. • Operating communities for network owners who contract the Platform: administering your membership, showing your profile to other members according to what you choose to share, moderating content, running courses and issuing certificates, and — where the network charges — handling membership billing. • Security and fraud prevention: detecting abusive uses, protecting service integrity and detecting cheating in an event's game activities. • Service communications: operational notifications, technical support, notices about changes to this policy or terms. Depending on the event or network, these may reach you by email, as an in-platform notification or as a browser notification. You can opt out of each channel separately, as explained in the notifications section. • Compliance with legal obligations: responding to requirements from competent authorities or fulfilling applicable regulations. • Aggregated and anonymized product improvement, on every plan: we analyse statistically how the Platform is used —which sections are visited, which features are used, at which step a flow is abandoned— to run, secure and improve the service. The results are aggregated and do not allow identifying a person: we do no individual tracking for our own purposes and build no attendee profiles. An event's activity log is kept on behalf of the organizer, who is its controller and to whom we show their own metrics; we use it for our own purposes only in aggregated and anonymized form. It also includes a technical measurement of how the interface responds (which part of the screen is tapped, how long it takes to respond, whether it freezes), which stores no identifiers, no IP addresses, no on-screen text or anything you type, leaves no cookies or data on your device, and is deleted after 30 days. • Measuring our acquisition campaigns, only on our website: we share pseudonymized identifiers with Meta and Google to learn which ads work, subject to your cookie consent. On events and their portals we run no advertising measurement, on any plan: we share no attendee identifiers for advertising and we do not measure attendees as people, neither for ourselves nor for third parties. There, only the aggregated and anonymized measurement described above and the count in the next point happen, and they identify no one. • Aggregate visit and registration count, on every plan: with Google Analytics we count how many visits each page of an event's portal receives and how many registrations are completed on its form, to run and improve the platform and tell the organizer how many visits their event had. It works without cookies or data stored on your device and without any Circli identifier (name, email, phone or account); addresses are sent without access codes and without the ids of conversations, posts or documents; from the registration form only the page address travels, plus the campaign parameters if you arrived from a campaign of ours. Google signals and ad personalization are turned off. As with any web page, Google receives the IP address and browser type when the tag loads; we do not use them to identify you. It is never used for advertising. On top of that there is the visit measurement of our hosting provider (Vercel), which counts the application's page views and, like any web server, receives the request's IP address and browser type; its reports are aggregate, carry no Circli identifier and are likewise never used for advertising. We do not use your data for our own commercial purposes other than the above, and we do no individual tracking of attendees for our own purposes. We do not sell, lease or transfer your data to third parties.
6. Processors and sub-processors
To operate the Platform we work with the following providers. Each processes data in a specific role and for a specific purpose, under agreements imposing confidentiality, security and purpose-limitation obligations. Processors (they process data on our behalf and on our instructions): • Meta Platforms, Inc. — messaging provider for the paid notices an organizer turns on — United States. • Vercel, Inc. — application hosting, storage of files uploaded to the Platform (profile photos, decks, logos, community materials), aggregate measurement of application visits (identifying nobody) and, on the forms where it is enabled, the technical check that whoever is filling them in is not a robot — United States and São Paulo, Brazil. • Supabase, Inc. — database — São Paulo, Brazil. • OpenAI, L.L.C. — natural-language processing, audio transcription, vector representations of profile text for the recommendations, and reading the image of donation receipts, under business terms that do not allow model training on our data — United States. • Anthropic PBC — natural-language processing for the people recommendations and other artificial-intelligence features, under commercial terms that do not allow model training on our data — United States. • Resend, Inc. and Google LLC (mail delivery) — delivery of Platform emails — United States. • Upstash, Inc. — rate limits, temporary verification codes and short-lived technical data of the session and the game (internal account and device identifiers, no name or contact details) — United States. • Functional Software, Inc. (Sentry) — application error logging — United States. • HubSpot, Inc. — business contact management (organizers and prospects, not attendees) — United States. • Google LLC (Google Wallet) — issuing the access pass, when the event enables it — United States. • Google LLC (Google Calendar and Google Meet) — arranging the demos booked on the site: the name and email of whoever books are stored in our sales team's calendar — United States. • Google LLC, Apple Inc., Mozilla Foundation and Microsoft Corporation (browser push services) — delivery of browser notifications to the device that enabled them. They only carry the notification: the content travels encrypted with your own browser's keys — United States. Independent controllers (they decide for themselves how they process what they receive): • Mercado Pago (Mercado Libre S.R.L.) — billing for community memberships. It receives and decides on your payment method data, which is not replicated in our systems; its own privacy policy applies. We do not determine the region in which it processes that data. • Google LLC (Google Analytics, Google Ads) — measurement of our site and campaigns, and aggregate count of event-portal visits and completed registrations (cookieless) — United States. • Google LLC (Google Maps and Google Places) — searching for and displaying the event venue, when the organisation uses the place search or when you open the map from the Platform. It receives the search query or the map opening, not your registration — United States. • Meta Platforms, Inc. (Pixel, Conversions API) — measurement of our campaigns — United States. • Giphy, Inc. — GIF search; if you use the picker, your browser connects directly to their service — United States. The advertising measurement described above happens only on our website, subject to your cookie consent: it does not happen on events or their portals, on any plan. The aggregate visit and registration count is not advertising measurement: it uses no cookies and shares no identifiers. The up-to-date list is available on the Sub-processors page.
7. Cookies and similar technologies
The Platform uses cookies and similar technologies in three categories: • Essential: necessary for site operation and session. They do not require your consent. • Analytics: help us understand how the site is used. If you visit from outside the European Economic Area, the United Kingdom or Switzerland they are on by default and you can reject them at any time from the cookie banner; inside those regions they only run after you accept. • Marketing: used to measure and optimize advertising campaigns. Same rule: on by default outside the European Economic Area, the United Kingdom and Switzerland, with an opt-out at any time from the banner; inside those regions only after you accept. On event portals and registration forms we use no analytics or marketing cookies: the aggregate count described in section 5 works without cookies or data stored on your device. How long they last. The essential cookies that keep you signed in (your account, the organizer panel, a network owner's panel) last seven (7) days from the moment you sign in; using the Platform does not extend that window. Those serving a single step — verifying your phone, completing a Google sign-in, confirming a second factor — live only as long as that step and are deleted when it ends. The cookie remembering your trusted device for two-factor authentication lasts seven (7) days. Your choice about analytics and marketing is not stored in a cookie but in your browser's local storage, and remains until you change it or clear the site's data. You can change your preferences at any time via the "Cookies" link in the footer.
8. Use of artificial intelligence
We use third-party artificial-intelligence services to process natural-language queries and categorize content on the Platform. Data sent to these services is processed under enterprise/business terms that prohibit its use for model training. You may request human review of any automated response at any time by contacting us. Suggestions about who to connect with. When an event or a network enables networking suggestions, we send the artificial-intelligence provider only the professional fields of the profiles: role, company, category, what you are looking for, what you offer and — if you filled it in — your bio, all truncated. We never send your name, phone number, email address or photo: profiles travel numbered, not identified. So that we can review and improve the quality of those suggestions, we keep a copy of the queries sent to the model, pseudonymized before storage — people's identifiers are replaced by a pseudonym and the text is stripped of names, phone numbers, emails and web addresses. Those copies are deleted automatically after one year. The pseudonym is always computed the same way precisely so that, if you request erasure of your data, we can also find and delete the queries in which you appeared as a candidate. If your event enables filling your profile by voice, your recording is sent to that provider for the sole purpose of transcribing it and suggesting fields to you. Circli does not keep the audio once transcribed, and you can always type instead of recording.
9. Events as a special context
When an organizer contracts the Platform to run an event, certain visitor data is shared with that organizer (for example: name, company, professional category, connections generated during the event). The organizer is the controller of that data. Each event has its own complementary privacy notice with event-specific uses. We recommend you read it when you join an event. What else happens inside an event. If the event enables chat, you can message other attendees: those messages are not end-to-end encrypted, the organizing team does not read your private messages and only sees one if somebody reports it for moderation. If the event uses live activities (questions to the speaker, polls, word clouds), we store your answer linked to your account even when it is displayed on screen without your name. If there is QR check-in, your entry is recorded, with the time and who checked you in. And if the event runs a game activity with booth scanning, what the data-collection section says about the approximate location of the scan applies. Booth contacts. If the event enables it, an exhibiting or sponsoring company's team can scan the QR on your card to request your contact. Scanning does not hand over your data: a request reaches your phone naming the company, and only if you tap «Share» does the company receive your name, company, role, your account phone number and, if you added them to your event profile, your email, another phone number and contact links, together with the date of the request; its team may add notes and a rating. When scanning, the booth team sees your name and company so they know whom they are asking. The company may use the data only to contact you about your interest in the event, and has previously accepted terms that forbid selling or transferring it. The transfer is decided by the Event Organizer, the controller of that data, and Circli carries it out on its behalf as processor; once it receives the data, the company is responsible for its use under Article 11 of Argentine Law 25,326. You can withdraw that consent and exercise your rights of access, rectification and deletion at any time, with the Organizer or by writing to privacidad@circli.app; we tell the company to stop using the data.
10. Minimum age and responsible communication
The Platform is intended for individuals over eighteen (18) years of age, except at events where the organisation expressly declares that it admits under-18s. At those events a minor takes part with the authorisation of whoever holds parental responsibility or guardianship: obtaining and keeping it is up to the event's organisation, which is the controller of that data. Circli neither requests nor stores it. We do not ask for or store anyone's date of birth. At those events, when signing up a person is asked only whether they are under 18, and only the yes or the no is stored, because that is the only data needed to protect them (section 4 of Law 25.326). Anyone who declares being under 18 has the artificial-intelligence features switched off: voice dictation, AI-written profile and people recommendations, so they receive no contact suggestions and are never offered as a suggestion to others. That switch-off follows the person across every event and community, not only the event where they declared it, and is not reversed if the organisation stops admitting minors. When an event involves the promotion of alcoholic beverages, compliance with Argentine Law 24,788 on responsible communication is up to the event's organisation, which decides and controls that content.
11. Storage and international transfers
The Platform runs on international infrastructure providers, so your data is processed outside Argentina: • Database: hosted in São Paulo, Brazil. • Files you upload (profile photos, decks, logos, community materials): in our hosting provider's storage, which operates in the United States and São Paulo, Brazil. • Web application: some functions run in São Paulo, Brazil, and the rest in our hosting provider's default region, in the United States. • Email, error logging, rate limiting, artificial intelligence and delivery of browser notifications: United States. • Billing for community memberships: processed by Mercado Pago, which decides for itself where and how it processes payment method data. We do not determine its processing region; if an international transfer is involved, the safeguards described below apply, along with its own privacy policy. • Content delivery network: global — public content may be served from the node closest to you. Neither Brazil nor the United States appears on the Argentine list of countries with an adequate level of protection. Accordingly, these international transfers are made under the safeguards provided by AAIP Disposition N° 60/2016 (model contractual clauses) and related regulations. We maintain agreements with each provider imposing confidentiality, security, purpose-limitation and return-or-destruction obligations. You can request the current detail of which service processes which data and in which region by writing to privacidad@circli.app. By using the Platform you expressly authorize this international transfer.
12. Data retention
We retain personal data only for the time necessary to fulfill the purposes described or as required by law. Typical periods: • Active account data: until you close your account. • Event data (activated profile): up to twenty-four (24) months post-event, with the organizer's authorization under art. 25 inc. 2 of Law 25,326. • Pre-registered users who did not activate a profile: deleted within seven (7) calendar days after the event closes, keeping only aggregate event figures. • Event chat messages: open-channel messages are deleted automatically after twelve (12) hours; direct messages after one hundred and eighty (180) days. • Community content (posts, comments, library, courses): kept for as long as the network exists, because it is the community's body of work rather than an operational log. You can delete your own posts and comments at any time; a library contribution you can withdraw while it is awaiting approval, and once published it is the network's council that takes it down. An erasure request covers all of it. • Notifications already delivered to your in-Platform inbox: thirty (30) days in events, ninety (90) days in communities. • Activity logs inside an event and support logs: ninety (90) days. • Pseudonymized copies of the queries sent to the artificial-intelligence model: one (1) year. • Browser notification subscription: for as long as you keep it active. It is deleted when you turn it off, when your browser revokes it and when your account is deleted. • Backups: kept for the retention window our database provider applies and continuously overwritten; deleted data may survive in them until the corresponding copy expires. • Records of consent and its withdrawal: kept for as long as they may be needed to evidence compliance and to defend against claims. After these periods, data is destroyed or irreversibly disassociated, except where legal obligations require its retention. What survives an erasure, and why. When we delete your personal data, some records are not deleted because they are evidence of something that happened rather than a description of you: invoices and payment receipts, which tax rules require us to keep for up to ten (10) years; audit logs of access and administrative actions; the record that an access pass was issued; and the record that a message was sent. None of those records is used to contact you again or to reconstruct your profile.
13. Your rights over your data
Under Argentine Law 25,326 you have the following rights over your personal data: • Access: request and receive information about the data we process. • Rectification: ask us to correct inaccurate or outdated data. • Erasure: ask for deletion of your data when applicable. • Objection: object to processing in certain circumstances. • Confidentiality: have your data treated with privacy. • Withdrawal of consent: withdraw your consent when it is the basis of processing. How to exercise them: • If your data was generated within an event operated on the Platform → contact the event organizer first; they are the controller of that data. Circli cooperates with the organizer. • If your data was generated inside a Circli Networks community → for the answers in your membership application the controller is the network owner; for your account and cross-cutting data, Circli. Write to us at privacidad@circli.app either way and we will route it. • If your data was generated by direct use of the landing or app outside an event — including creating an account with email and password or with your Google account → contact us at privacidad@circli.app. Statutory deadlines we observe (Law 25,326): access requests are answered within ten (10) calendar days of receipt; rectification, update or erasure requests are resolved within five (5) business days. Where your data was disclosed to a third party, we notify them of the rectification or erasure within the fifth business day. You also have the right to file complaints with the Agency for Access to Public Information (AAIP). If you reside in the European Union, you may exercise equivalent rights under the GDPR.
14. Data security
We implement reasonable technical and organizational measures in line with AAIP Resolution N° 47/2018 and industry best practices, including: • Encryption in transit (HTTPS/TLS) and at rest, as provided by our infrastructure providers. • Access controls with a second factor on the admin and organizer panels, and the principle of least privilege. • Salted hashing of IP and user-agent in consent records and agreement acceptances. • Backups managed by our database provider. • Confidentiality duties for personnel with access to personal data. In the event of a security incident affecting your personal data, we commit to notifying within seventy-two (72) hours of reasonable confirmation, in line with international best practices.
15. Registration and supervisory authority
CIRCLI SERVICIOS TECH S.A.S. is registered as a data controller with the AAIP's National Registry of Personal Data Bases under file RL-2026-96127867-APN-DNPDP#AAIP, together with its "Platform users" and "Business contacts" databases. Those two databases are the ones Circli processes on its own account. An event's attendee roll and a community's member list are not among them, and that is deliberate: for those databases the controller is the event organizer or the community owner, and Circli processes them as a processor, on their behalf and under their instructions (section 25, Law 25,326). Each of them is the one who must register their own database and publish their own policy. We will still help you reach them. This does not cover the data Circli is a controller of even when you used it inside an event or a community: your account and access credentials, payment data, audit and consent records, notification subscriptions and the platform's own measurement. The full allocation is in sections 2, 13 and 16. The Agency for Access to Public Information (AAIP) is the body overseeing compliance with Law 25,326 in the Republic of Argentina. You have the right to file complaints with it.
16. Privacy in Circli Networks
If you participate in a private Circli Networks circle (a paid-membership community), these additional rules apply: • Dual controllership. The network owner is the controller of the data you complete in the application form (motives, context, answers to the questionnaire) — that data is visible to the network's council and is not exposed to the public. Circli is the controller for cross-cutting data (identity and sign-in credentials — your email, or your phone if you gave one —, payment data, audit logs, subscriptions) and acts as processor when operating the platform on the owner's behalf. • Visibility default: members-only. Your network profile (display name, photo, headline, bio) is visible only to active members of the same network, and only if you choose to appear in the directory. • Your contact details are published one by one, and only if you switch them on. There is a separate toggle for each channel: email, phone, LinkedIn, X, Instagram, Telegram, GitHub and website. In a community they all start off: a profile you never touched publishes no contact detail at all, not even to fellow members. If the network additionally restricts contact to internal messaging, that restriction adds to your choice and never overrides it: between the two, the more closed one always wins. • Confidentiality — Chatham House. Anything that circulates inside the network (posts, weekly brief, intro threads, concierge messages) you may use as information but may not attribute without permission. This is a community norm, not a legal obligation, but breaking it may lead to council sanctions. • Double-opt-in introductions. When you ask to be introduced to another member, we store the reason and context you write. Your contact details are not revealed until both parties have accepted. The network owner or council takes part in the approval and sees that request; a record of each introduction is retained in our systems for audit. This is separate from the directory: if you appear in the directory, other members can see your profile and contact you through the channels you have switched on. • Courses, assessments and certificates. If the network runs courses, we record your progress, your quiz answers and their result, and the practice steps you tick off. The network owner and council see aggregate figures for the course — how many people reached each lesson and how many finished it — not your individual result. Your study notes are private: no screen shows them to another member or to the owner. If you complete a course you can obtain a certificate with a verification page on the internet, reachable by anyone holding the link: the link is not guessable, and sharing it is your decision. • Participation and reputation. If the network enables them, you accumulate points, badges and participation levels derived from what you do inside the community, visible to other members and to the council. We do not use them outside the network or for advertising. • If you follow a network without being a member. Networks may have a public page where you leave your email — and, if you want, your phone number — to receive updates. We use that data only to send you those updates and to know which link you arrived from; you can unsubscribe from any of those messages. • Paid membership. If the network charges, the payment is processed by Mercado Pago and your payment method data stays with Mercado Pago, not with Circli. The network owner sees the amount due to them, never your card details. • Community messages. A community's chat is not end-to-end encrypted and, unlike an event's chat, is not deleted automatically: it is kept for as long as the network exists. Do not use it for confidential information. • Deletion. You may request deletion of your network data by writing to privacidad@circli.app or through the request form on the site. We delete your profile, your posts and comments, your participation in intro threads, your notes and your course progress. Invoices and audit logs are retained as legally required (up to ten years). If you have an outstanding charge or an open dispute, deletion is deferred until it is resolved and we tell you so when we reply. Operational detail in the Circli Networks Member Handbook.
17. Notices and notifications
We contact you through two channels, and you can leave both. There is also a third, paid one, which exists only at events whose organizer buys it, and you can leave it too: • Email. All of our update emails carry an unsubscribe link and the standard header that lets you unsubscribe from your own mail program. Strictly operational emails — an access code, a payment confirmation, the reply to a request you made — have no opt-out, because they are part of the service you asked for. • Browser notifications. These are optional and start off: you only receive them if you enable them from your profile. You can turn them off there, and in that case we delete your device's delivery address. You can also revoke the permission from your browser settings: that stops delivery immediately, and we delete the address as soon as the push service tells us it is no longer valid. • An event's special notice. A one-off message to your phone that the organizer of an event you take part in can send if they buy that paid service; it is delivered by Meta Platforms, the messaging provider listed in section 6. It only goes out at events that turn it on, and only to people who added their number. You stop receiving it by switching off «Automatic notifications» in your profile, which applies to all your events, or with the unsubscribe link in that event's emails. Opting out of a channel does not cancel your account or your membership, and does not remove your access to anything. If you want to stop receiving everything and also have your data deleted, that is an erasure request: use the request form or write to privacidad@circli.app.
18. Changes to this policy
This Policy may be updated to reflect regulatory changes, new functionality, or improvements in our practices. When changes are substantial, we will notify you through the usual channels (website, app or email). The date of last update appears at the top of the document.
19. Contact
For inquiries, complaints or to exercise rights over your data, write to privacidad@circli.app. You may also reach us via the contact form on the site. Controller: Circli Servicios Tech S.A.S., CUIT 30-71944030-0, City of Mendoza, Argentina.