PRIVACY POLICY - CIRKLR

Effective from: 2025-11-01

Copyright © 2025 Cirklr | 112 65 Stockholm

At Cirklr, we value your privacy. 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

Organization number: 900709-XXXX

Address: 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 (Premium).
  • 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

All data is stored within the EU/EEA. If personal data in exceptional cases is transferred outside the EU/EEA, protection is ensured through EU Standard Contractual Clauses (SCC).

7. Data Security

We use technical and organizational security measures, including:

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

Only authorized 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: Up to 24 months after inactivity
  • Payment data: 7 years in accordance with accounting laws
  • Support cases: Up to 24 months

Upon account deletion, data is deleted or anonymized 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 minors. If such information is discovered, it will be deleted immediately.

14. Third-Party Services

We use third-party services for:

  • Server operations
  • Email distribution
  • Payment processing

All providers are bound by GDPR and confidentiality agreements.

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

© Cirklr 2025