Privacy Policy

1. Introduction

Circle4Pro ("we," "our," or "us") respects your privacy and is committed to protecting your personal data. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application, website, and related services (collectively, the "Platform").

We are registered in the United Arab Emirates and comply with Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (PDPL), as well as other applicable data protection laws.

This Privacy Policy applies to all users of the Platform, including Seekers, Experts, and visitors. By using the Platform, you consent to the data practices described in this policy.

2. Data Controller and Contact Information

Data Controller: Circle4Pro, Dubai Sports City, Dubai, UAE.

Privacy Contact:

1. Email: info@circle4pro.com
2. Phone: +971 54 445 9033

For privacy-related inquiries or to exercise your data protection rights, please contact us using the details above.

3. Information We Collect

We collect various categories of personal data to provide and improve our services. The types of information we collect depend on how you interact with the Platform.

3.1 Account and Profile Information

When you create an account, we collect:

1. Full name
2. Email address
3. Password (hashed and encrypted)
4. Profile picture or avatar
5. Preferred language
6. Timezone
7. Bio or headline
8. Location details (city, country)

3.2 Identity Verification Data (For Experts)

To verify Expert status, we collect:

1. Government-issued photo ID (e.g., passport, national ID, driver's license)
2. Visual verification selfie photo
3. Professional certifications and qualifications
4. Work experience details
5. Company name and website URL
6. Social media profile links

3.3 Financial and Payment Information

All payment-related information is processed securely through Stripe and Stripe Connect Express. We do not store full credit/debit card numbers on our servers. We may collect:

1. Billing address
2. Transaction history (purchases, refunds, payouts)
3. Bank account details for Expert payouts (processed via Stripe Connect Express)

3.4 User-Generated Content and Communications

When you interact with the Platform, we collect:

1. Question descriptions and consultation details
2. Image attachments (up to 3 per Q&A)
3. Voice recordings
4. Direct chat messages
5. Uploaded media and documents
6. Consultation reviews and star ratings
7. Circle and training program interactions

3.5 Usage Data and Technical Information

We automatically collect certain information when you use the Platform, including:

1. Device information (type, model, operating system, unique device identifiers)
2. IP address
3. Browser type and version
4. Log data (access times, pages viewed, features used)
5. App performance and crash reports
6. Referral source and navigation paths

3.6 Location Information

With your consent, we may collect precise geolocation data to:

1. Enable location-based filtering and discovery
2. Provide relevant local service recommendations

3.7 Device Permissions

The Platform may request access to:

1. Camera and Photo Library: For uploading profile pictures, verification documents, Q&A attachments, and chat media
2. Microphone: For video/audio calls and voice messages
3. Push Notifications: For alerts, reminders, and call signaling
4. Storage: For caching and accessing media files

You can manage these permissions in your device settings.

4. How We Use Your Information

We process your personal data for the following purposes:

You may opt out of marketing communications at any time.

5. Legal Basis for Processing

We process your personal data on the following lawful bases under UAE PDPL:

Consent, where required, must be freely given, specific, informed, and unambiguous.

6. How We Share Your Information

We may share your personal data with the following categories of recipients:

6.1 Third-Party Service Providers

We engage trusted third-party providers to perform services on our behalf:

6.2 Other Users

Information you choose to share on the Platform may be visible to other users:

1. Profile information: Visible to Seekers and Experts;
2. User-generated content: Posts, reviews, and comments are publicly visible within the relevant context;
3. Expert listings: Available to all users.

6.3 Legal and Regulatory Authorities

We may disclose your personal data if required to:

1. Comply with a legal obligation (e.g., court order, subpoena);
2. Protect the rights, property, or safety of us, our users, or others;
3. Prevent or investigate fraud or security incidents.

6.4 Business Transfers

In the event of a merger, acquisition, reorganisation, or sale of assets, your personal data may be transferred as part of the transaction. You will be notified via email and/or a prominent notice on the Platform.

7. International Data Transfers

Your personal data may be transferred to, stored, and processed in countries outside the United Arab Emirates, including:

1. United States (Stripe, Google, Agora, SendGrid);
2. European Union (Agora);
3. Other jurisdictions where our service providers operate.

We ensure that such transfers comply with UAE PDPL requirements by:

1. Implementing standard contractual clauses (SCCs) or equivalent safeguards;
2. Ensuring recipients provide adequate data protection measures;
3. Obtaining your explicit consent where required by law.

8. Data Retention

We retain your personal data only for as long as necessary to fulfil the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.

Upon account deletion, we will:

1. Anonymise or delete your personal data;
2. Retain only information necessary for legal compliance, fraud prevention, or dispute resolution.

9. Your Privacy Rights

Under UAE PDPL, you have the following rights regarding your personal data:

To exercise these rights, please contact us at info@circle4pro.com. We will respond within 30 days (or as required by applicable law).

10. Data Security

We implement appropriate technical and organisational measures to protect your personal data:

10.1 Technical Measures

1. Encryption: Data in transit (TLS/SSL) and at rest (AES-256);
2. Access Controls: Role-based access, multi-factor authentication;
3. Secure Payment Processing: PCI DSS compliant (via Stripe);
4. Regular Security Assessments: Vulnerability scanning and penetration testing;
5. Intrusion Detection: Monitoring and alerting systems.

10.2 Organisational Measures

1. Data protection policies and training;
2. Limited access to personal data on a need-to-know basis;
3. Incident response and breach notification procedures;
4. Third-party vendor security assessments.

10.3 Data Breach Notification

In the event of a data breach that affects your personal data, we will:

1. Notify the UAE Data Office without undue delay and, where feasible, not later than 72 hours after becoming aware of the breach;
2. Notify affected individuals if the breach is likely to result in a high risk to their rights and freedoms;
3. Provide information on the nature of the breach and recommended actions.

11. Children's Privacy

Minimum Age Requirement: You must be 13 years of age or older to use the Platform. Users under the age of 18 may only use the Platform with the consent and supervision of a parent or legal guardian. We do not knowingly collect personal data from individuals under 13. If we become aware that we have collected data from a minor under 13, we will delete it promptly.

If you are a parent or guardian and believe your child has provided us with personal data, please contact us immediately.

12. Third-Party Links and Services

The Platform may contain links to third-party websites, applications, or services. This Privacy Policy does not apply to such third parties. We are not responsible for the privacy practices or content of external sites. We encourage you to review their privacy policies before providing any personal information.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, legal requirements, or technology.

13.1 Notification of Changes

We will notify you of material changes by:

1. Posting the updated policy on the Platform;
2. Sending a notification to your registered email address;
3. Displaying a prominent notice on the Platform.

13.2 Effective Date

The "Last Updated" date at the top of this policy indicates when it was last revised. Your continued use of the Platform after changes become effective constitutes acceptance of the updated policy.

14. Complaints and Dispute Resolution

14.1 Internal Complaint Process

If you have a privacy-related complaint, please contact us at:

1. Email: info@circle4pro.com

We will acknowledge receipt within 7 days and aim to resolve complaints within 30 days.

14.2 Regulatory Authority

If you are not satisfied with our response, you have the right to lodge a complaint with the UAE Data Office (or the relevant supervisory authority).

14.3 Governing Law

This Privacy Policy shall be governed by and construed in accordance with the laws of the United Arab Emirates.

15. Consent and Opt-Out

15.1 Consent Mechanism

By using the Platform, you consent to the collection, use, and disclosure of your personal data as described in this Privacy Policy.

15.2 Opt-Out Rights

You may withdraw your consent at any time by:

1. Adjusting your account preferences;
2. Contacting us via email;
3. Deleting your account.

Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

16. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy, please contact us at:

Circle4Pro

1. Email: info@circle4pro.com
2. Address: Dubai Sports City, Dubai, UAE.
3. Phone: +971 54 445 9033

Note: This document is a draft for informational purposes only and does not constitute legal advice. You are strongly advised to have this Privacy Policy reviewed by a qualified legal professional licensed to practice in the United Arab Emirates before publication or implementation.