CIRKLR

Privacy policy

PRIVACY POLICY - CIRKLR

Effective from: 2025-11-01

Cirklr respects the privacy of every user. This privacy policy describes how we collect, use, store, and protect your personal data when you use our platform. By creating an account or using Cirklr, you agree to this policy.

1. Data Controller

Cirklr

Operated by Clément Joye as a sole trader.

Address: Badstrandsvägen 24, 112 65 Stockholm, Sweden

Email: support@cirklr.com

Country: Sweden

Cirklr is the data controller for all processing of personal data under this policy.

2. What Personal Data We Collect

We only collect data that is necessary to operate and secure the service:

Account Information

Email address
Phone number
Username
Encrypted password

Profile Information (optional)

Location or area

User Data

Items you list, lend, or request
Messages via the platform chat
Status history and activity logs

Technical Information

IP address
Browser type and version
Operating system

3. Legal Basis for Processing

The processing of your personal data is based on the following legal grounds under GDPR Article 6:

Contract: To provide the service.
Legal obligation: For accounting and payments (membership).
Legitimate interest: For security, operation, and abuse prevention.
Consent: For optional profile data and cookies.

4. How We Use Your Data

Personal data is used solely to:

Operate the platform and enable sharing, requests, and communication
Ensure platform security
Provide customer support
Maintain and improve system stability

We do not use personal data for marketing, tracking, or profiling.

5. Sharing of Personal Data

Cirklr never sells, rents, or shares personal data for commercial purposes.

Data may only be shared:

When required by law or authority decision
With technical service providers (e.g., hosting, email, payment) under data processing agreements in accordance with GDPR

6. Transfers to Third Countries

Cirklr primarily uses Microsoft Azure hosting in North Europe, West Europe and Sweden.

Support correspondence is handled through Proton Mail. According to Proton’s privacy policy, its mail servers are located in Switzerland, Germany or Norway. Switzerland is outside the EU/EEA and is recognised by the European Commission as providing an adequate level of data protection.

Transfers of personal data outside the EU/EEA require an applicable adequacy decision or other appropriate safeguards, such as EU Standard Contractual Clauses (SCC).

7. Data Security

We use technical and organisational security measures, including:

Encrypted transmission (HTTPS)
Encrypted password storage
Access restrictions
Continuous security monitoring

Only authorised personnel have access to personal data when necessary.

8. Data Retention

Personal data is retained only as long as necessary:

Account information: As long as the account is active
Messages and activity logs: No fixed deletion period is currently applied. You can request deletion by emailing support@cirklr.com.
Payment data: 7 years in accordance with accounting laws
Support enquiries: No fixed deletion period is currently applied. You can request deletion by emailing support@cirklr.com.

Upon account deletion, data is deleted or anonymised unless continued storage is required by law.

9. Your Rights Under GDPR

You have the right to:

Request a data extract
Have incorrect data corrected
Request erasure
Request restriction of processing
Object to processing
Receive your data (data portability)

You also have the right to lodge a complaint with:
The Swedish Authority for Privacy Protection (IMY) - www.imy.se

Requests should be sent to: support@cirklr.com

10. Automated Decision-Making

Cirklr does not use automated decision-making or profiling under GDPR Article 22.

11. Cookies

We use only technical cookies for:

Login
Session management

No tracking, advertising, or third-party cookies are used.

12. Personal Data Breaches

In the event of a personal data breach, affected users and supervisory authorities will be informed in accordance with GDPR.

13. Children’s Privacy

Cirklr is not intended for children under the age of 16. We do not knowingly collect data from children under 16. If such information is discovered, it will be deleted immediately.

14. Third-Party Services

Cirklr uses:

Microsoft Azure for hosting, authentication and service emails.
Stripe for payment processing.
Proton Mail for the support mailbox. If you email support@cirklr.com, your email address and message are handled through Proton Mail.

15. Changes to This Policy

In the event of material changes, you will be informed via:

Email
The platform

The latest version is always available on the Cirklr website.

16. Contact

Cirklr Support

📧 support@cirklr.com