Last Updated: Jan 5th, 2023

CircleIn (“CircleIn”) is committed to protecting your privacy. We have prepared this
Privacy Policy to describe to you our practices regarding the Personal Data (as defined
below) we collect from users of our website, located at www.CircleInApp.com and our
mobile application (“Application(s)”) (collectively, the “Site”) and online services
(“Services”).
This Privacy Policy does not govern any school’s collection, use, or disclosure of
personal information through the Site or Service, and we are not responsible for any
such collection, use, or disclosure. Parents, please contact your child’s school to
understand the school’s privacy practices.

1. Questions; Contacting CircleIn; Reporting Violations. If you have any
questions or concerns or complaints about our Privacy Policy or our data
collection or processing practices, or if you want to report any security
violations to us, please contact us at the following email address:
CircleIn
Hello@CircleInApp.com

2. User Consent. By submitting Personal Data through our Site or Services or
permitting your Child to submit Personal Data through our Site or Services, you
agree to the terms of this Privacy Policy and you expressly consent to the
collection, use and disclosure of your or your student’s Personal Data, as
applicable, in accordance with this Privacy Policy. Users under the age of 13
(“Children”, each a “Child”) may only use the Site and Services with the prior
consent of a parent or legal guardian, which has been provided to CircleIn in
the manner directed by the Services. The term “You” or “you” as used herein
refers to the individual or entity interacting with our Site or Services.

3. A Note to Users Outside of the United States. If you are a non U.S. user of
the Site, by visiting the Site and providing us with data, you acknowledge
and agree that your Personal Data may be processed for the purposes
identified in the Privacy Policy. In addition, your Personal Data may be
processed in the country in which it was collected and in other countries,
including the United States, where laws regarding processing of Personal
Data may be less stringent than the laws in your country. By providing your
data, you consent to such transfer.

4. Types of Data We Collect. “Personal Data” means data that allows someone
to identify or contact you, including, for example, your name, address,
telephone number, e-mail address, as well as any other non-public information
about you that is associated with or linked to any of the foregoing data.
“Anonymous Data” means data that is not associated with or linked to your
Personal Data; Anonymous Data does not, by itself, permit the identification of
individual persons. We collect Personal Data and Anonymous Data, as described
below.

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(a) Information Student Users Provide to Us. We may request and collect
certain information when you visit our Site. However, student users are
required to disclose only the information that is reasonably necessary to
participate in the Services. The following section applies to student users who
use our Site or access the Services.
• We may collect Personal Data from you, such as your first and last
name, state, school, grade level, gender, user name, password and
e-mail address, when you create an account to log in to our
network (“Account”).
• When you redeem for rewards on our Site, we will collect all
information necessary to complete the transaction, including your
name and shipping information. This information may be shared
with third parties who help process and fulfill your reward
redemptions.
• We retain information on your behalf, such as files and messages
that you store using your Account.
• If you provide us feedback or contact us via e-mail, we will collect
your name and e-mail address, as well as any other content
included in the e-mail, in order to send you a reply.
• When you post content (text, images, photographs, messages,
comments or any other kind of content that is not your e-mail
address) on our Site, the information contained in your posting will
be stored in our servers and other users will be able to see it, along
with your profile photo and any other information that you choose
to make available on your profile page (“Profile”).
• When you post messages on the message boards of our Site, the
information contained in your posting will be stored on our servers
and other users will be able to see it.
• When you participate in one of our surveys, we may collect
additional profile information.
• If you participate in a sweepstakes, contest or giveaway on our
Site, we may ask you for your e-mail address and/or home number
(to notify you if you win or not). We may also ask for first and last
names, and sometimes post office addresses to verify your identity.
In some situations we may need additional information as a part of
the entry process, such as a prize selection choice. These
sweepstakes and contests are voluntary. We recommend that you
read the rules for each sweepstakes and contest that you enter.
• We may also collect Personal Data at other points in our Site that
state that Personal Data is being collected.
(b) Information Parents Provide to Us. When parents or legal guardians
subscribe students to our Services, our third party payment provider will
collect payment and billing information in order to process the subscription
fee. For online payments and/or Automated Clearing House (ACH) payouts, we
use the payment services of Stripe (https://stripe.com). We do not process,
record or maintain your credit card or bank account information. For more
information on how payments are handled, or to understand the data security
and privacy afforded such information, please refer to https://stripe.com/us/
privacy.
(c) Information Schools Provide to Us. We will collect the following
personal information from schools about students who use our Service:
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(d) Information Collected via Technology.
• Information Collected by Our Servers. To make our Site and
Services more useful to you, our servers (which may be hosted by a
third party service provider) collect information from you, including
your browser type, operating system, Internet Protocol (“IP”)
address (a number that is automatically assigned to your computer
when you use the Internet, which may vary from session to session),
domain name, and/or a date/time stamp for your visit.
• Log Files. As is true of most websites, we gather certain
information automatically and store it in log files. This information
includes IP addresses, browser type, Internet service provider
(“ISP”), referring/exit pages, operating system, date/time stamp,
and clickstream data. We use this information to analyze trends,
administer the Site, track users’ movements around the Site, gather
demographic information about our user base as a whole, and
better tailor our Services to our users’ needs. For example, some
of the information may be collected so that when you visit the Site
or the Services again, it will recognize you and the information
could then be used to serve advertisements and other information
appropriate to your interests. Except as noted in this Privacy
Policy, we do not link this automatically-collected data to Personal
Data.
• Cookies. Like many online services, we use cookies to collect
information. “Cookies” are small pieces of information that a
website sends to your computer’s hard drive while you are viewing
the website. We may use both session Cookies (which expire once
you close your web browser) and persistent Cookies (which stay on
your computer until you delete them) to provide you with a more
personal and interactive experience on our Site. This type of
information is collected to make the Site more useful to you and to
tailor the experience with us to meet your special interests and
needs.
• Pixel Tags. In addition, we use “Pixel Tags” (also referred to as
clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic
images with a unique identifier, similar in function to Cookies, that
are used to track online movements of Web users. In contrast to
Cookies, which are stored on a user’s computer hard drive, Pixel
Tags are embedded invisibly in Web pages. Pixel Tags also allow us
to send e-mail messages in a format users can read, and they tell us
whether e-mails have been opened to ensure that we are sending
only messages that are of interest to our users. We may use this
information to reduce or eliminate messages sent to a user. We do
not tie the information gathered by Pixel Tags to our users’ Personal
Data.
• Flash LSOs. When we post videos, third parties may use local
shared objects, known as “Flash Cookies,” to store your
preferences for volume control or to personalize certain video
features. Flash Cookies are different from browser Cookies because
of the amount and type of data and how the data is stored. Cookie
management tools provided by your browser will not remove Flash
Cookies. To learn how to manage privacy and storage settings for
Flash Cookies, click here: http://www.macromedia.com/support/
documentation/en/flashplayer/help/settings_manager07.html.
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• Mobile Services. If you use our Services on your mobile device,
including through our Application(s), we may collect your phone
number and the unique device id number. When connecting to our
Services via a service provider that uniquely identifies your mobile
device, we may receive this identification and use it to offer
extended services and/or functionality. We may also collect nonpersonal information from your mobile device if you have
downloaded our Application(s). This information is generally used
to help us deliver the most relevant information to you. Examples
of information that may be collected and used include your
geographic location, how you use the Application(s), and
information about the type of device you use. In addition, in the
event our Application(s) crash on your mobile device, we will
receive information about your mobile device model software
version and device carrier, which allows us to identify and fix bugs
and otherwise improve the performance of our Application(s). This
information is sent to us as aggregated information and is not
traceable to any individual and cannot be used to identify an
individual.
• Analytics Services. We use third party analytics services, including
but not limited to Google Analytics (“Analytics Services”) to help
analyze how users use our Site and Services. We use the
information we get from Analytics Services only to improve our Site
and Services. The information generated by the Cookies or other
technologies about your use of our Site and Services (the “Analytics
Information”) is transmitted to the Analytics Services. The
Analytics Services use Analytics Information to compile reports on
user activity. The Analytics Services may also transfer the Analytics
Information to third parties where required to do so by law, or
where such third parties process Analytics Information on their
behalf. Each Analytics Service’s ability to use and share Analytics
Information is restricted by such Analytics Service’s Terms of Use
and Privacy Policy. By using our Site and Services, you consent to
the processing of data about you by Analytics Services in the
manner and for the purposes set out above. For a full list of
Analytics Services, please contact us at Hello@mqvo.com
5. Use of Your Personal Data
(a) General Use. In general, Personal Data you submit to us is used either
to respond to requests that you make, or to aid us in serving you better. We
use your Personal Data in the following ways:
• facilitate the creation of and secure your Account on our network; • identify you as a user in our system; • provide improved administration of our Site and Services; • provide the Services you request; • improve the quality of experience when you interact with our Site
and Services; • send you a welcome e-mail to verify ownership of the e-mail address
provided when your Account was created; • send you administrative e-mail notifications, such as security, or
support and maintenance advisories;
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• respond to your inquiries related to employment opportunities or
other requests; • send newsletters, surveys, offers, and other promotional materials
related to our Services and for other marketing purposes of CircleIn.
(b) User Testimonials and Comments. We often receive testimonials and
comments from users who have had positive experiences with our Services. We
occasionally publish such content. When we publish this content, we may
identify our users by their first and last name and may also indicate their home
city. We obtain the user’s consent prior to posting his or her name along with
the testimonial. If you make any comments on a blog or forum associated with
our Site, you should be aware that any Personal Data you submit there can be
read, collected, or used by other users of these forums, and could be used to
send you unsolicited messages. We are not responsible for the personally
identifiable information you choose to submit in these blogs and forums.
(c) Creation of Anonymous Data. We may create Anonymous Data records
from Personal Data by excluding information (such as your name) that makes
the data personally identifiable to you. We use this Anonymous Data to analyze
request and usage patterns so that we may enhance the content of our Services
and improve Site navigation. We reserve the right to use Anonymous Data for
any purpose and disclose Anonymous Data to third parties in our sole
discretion.
6. Disclosure of Your Personal Data. We disclose Personal Data as described
below and as described elsewhere in this Privacy Policy.
(a) Users. We will share your Personal Data with other Users solely for the
purpose of providing the Services.
(b) Third Party Service Providers. We may share your Personal Data with
third party service providers to: provide you with the Services that we offer
you through our Site; to conduct quality assurance testing; to facilitate
creation of accounts; to provide technical support; and/or to provide other
services to CircleIn. These third party service providers are required not to use
your Personal Data other than to provide the services requested by CircleIn.
(c) Affiliates. We may share some or all of your Personal Data with our
affiliates, subsidiaries, joint ventures, or other companies under a common
control (“Affiliates”), in which case we will require our Affiliates to honor this
Privacy Policy.
(d) Corporate Restructuring. We may share some or all of your Personal
Data in connection with or during negotiation of any merger, financing,
acquisition or dissolution transaction or proceeding involving sale, transfer,
divestiture, or disclosure of all or a portion of our business or assets. In the
event of an insolvency, bankruptcy, or receivership, Personal Data may also be
transferred as a business asset. If another company acquires our company,
business, or assets, that company will possess the Personal Data collected by us
and will assume the rights and obligations regarding your Personal Data as
described in this Privacy Policy.
(e) Social Networking Sites. Some of our Applications and Services may
enable you to post content to social networking services (“SNSs”) (e.g.,
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Facebook or Twitter). If you choose to do this, we will provide information to
such SNSs in accordance with your elections. You acknowledge and agree that
you are solely responsible for your use of those websites and that it is your
responsibility to review the terms of use and privacy policy of the third party
provider of such SNSs. We will not be responsible or liable for: (i) the
availability or accuracy of such SNSs; (ii) the content, products or services on
or availability of such SNSs; or (iii) your use of any such SNSs.
AS A RESULT, WE MAY PROVIDE YOUR PERSONAL DATA TO A THIRD PARTY COMPANY.
BECAUSE WE DO NOT CONTROL THE PRIVACY PRACTICES OF THESE THIRD PARTY
COMPANIES, YOU SHOULD READ AND UNDERSTAND THEIR PRIVACY POLICIES.
NOTICE TO CALIFORNIA RESIDENTS – YOUR CALIFORNIA PRIVACY RIGHTS
(AS PROVIDED BY CALIFORNIA CIVIL CODE SECTION 1798.83
A CALIFORNIA RESIDENT WHO HAS PROVIDED PERSONAL DATA TO A BUSINESS WITH
WHOM HE/SHE HAS ESTABLISHED A BUSINESS RELATIONSHIP FOR PERSONAL, FAMILY,
OR HOUSEHOLD PURPOSES (A “CALIFORNIA CUSTOMER”) MAY REQUEST
INFORMATION ABOUT WHETHER THE BUSINESS HAS DISCLOSED PERSONAL
INFORMATION TO ANY THIRD PARTIES FOR THE THIRD PARTIES’ DIRECT MARKETING
PURPOSES. IN GENERAL, IF THE BUSINESS HAS MADE SUCH A DISCLOSURE OF
PERSONAL DATA, UPON RECEIPT OF A REQUEST BY A CALIFORNIA CUSTOMER, THE
BUSINESS IS REQUIRED TO PROVIDE A LIST OF ALL THIRD PARTIES TO WHOM
PERSONAL DATA WAS DISCLOSED IN THE PRECEDING CALENDAR YEAR, AS WELL AS A
LIST OF THE CATEGORIES OF PERSONAL DATA THAT WERE DISCLOSED. CALIFORNIA
CUSTOMERS MAY REQUEST FURTHER INFORMATION ABOUT OUR COMPLIANCE WITH
THIS LAW BY E-MAILING Hello@CircleInApp.com PLEASE NOTE THAT WE ARE
REQUIRED TO RESPOND TO ONE REQUEST PER CALIFORNIA CUSTOMER EACH YEAR
AND WE ARE NOT REQUIRED TO RESPOND TO REQUESTS MADE BY MEANS OTHER
THAN THROUGH THIS E-MAIL ADDRESS.
(h) Public Profile and Postings. Certain portions of the information you
provide to us may also be displayed in your Profile. As an essential element of
the Services, most of the Personal Data you explicitly provide to us when you
register or update your Profile is displayed on your Profile. Your Profile is not
for public viewing but will be viewable by other users of our Services. We
cannot control who reads your postings or what other users may do with the
information that you voluntarily post, so it is very important that you do not
put Personal Data in your posts. Once you have posted information publicly,
while you will still be able to edit and delete it on the Site, you will not be able
to edit or delete such information cached, collected, and stored elsewhere by
others (e.g., search engines).
(i) Other Disclosures. Regardless of any choices you make regarding your
Personal Data (as described below), CircleIn may disclose Personal Data if it
believes in good faith that such disclosure is necessary (a) in connection with
any legal investigation; (b) to comply with relevant laws or to respond to
subpoenas or warrants served on CircleIn; (c) to protect or defend the rights or
property of CircleIn or users of the Site or Services; and/or (d) to investigate or
assist in preventing any violation or potential violation of the law, this Privacy
Policy, or our Terms of Use.
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7. Your Choices Regarding Information. You have several choices regarding the
use of information on our Service:
(a) Children’s Personal Data. We provide parents and legal guardians the
following choices regarding Children’s Personal Data. Parents and legal
guardians may access, change, and delete their Children’s Personal Data by
emailing hello@CircleInApp.com To access, change or delete information
collected by schools in connection with Site or Service which cannot be
accessed, changed or deleted as described above, please contact the school
directly. Parents and legal guardians may consent to our internal use of
Children’s Personal Data, but request that we refrain from sharing a Child’s
Personal Data with third parties by sending us an e-mail or postal mail at the
address above, provided that we may still share such Child’s Personal Data as
necessary to provide the Service. Parents and legal guardians may prohibit
future collection or use of their Children’s Personal Data by requesting
termination of the applicable Accounts.
(b) Email Communications. We will periodically send you free newsletters
and e-mails that directly promote the use of our Site or Services. When you
receive newsletters or promotional communications from us, you may indicate
a preference to stop receiving further communications from us and you will
have the opportunity to “opt-out” by following the unsubscribe instructions
provided in the e-mail you receive or by contacting us directly (please see
contact information above). Despite your indicated e-mail preferences, we
may send you service related communications, including notices of any updates
to our Terms of Use or Privacy Policy.
(c) Cookies. If you decide at any time that you no longer wish to accept
Cookies from our Service for any of the purposes described above, then you can
instruct your browser, by changing its settings, to stop accepting Cookies or to
prompt you before accepting a Cookie from the websites you visit. Consult your
browser’s technical information. If you do not accept Cookies, however, you
may not be able to use all portions of the Service or all functionality of the
Service. If you have any questions about how to disable or modify Cookies,
please let us know at the contact information provided above.
(d) De-Linking SNS. If you decide at any time that you no longer wish to
have your SNS account (e.g., Facebook) linked to your Account, then you may
de-link the SNS account in the “preferences” section in your account settings.
You may also manage the sharing of certain Personal Data with us when you
connect with us through an SNS, such as through Facebook Connect. Please
refer to the privacy settings of the SNS to determine how you may adjust our
permissions and manage the interactivity between the Services and your social
media account or mobile device.
(e) Changing or Deleting Your Personal Data. You may change any of your
Personal Data in your Account by hello@CircleInApp.com You may request
deletion of your Personal Data by us, and we will use commercially reasonable
efforts to honor your request, but please note that we may be required to keep
such information and not delete it (or to keep this information for a certain
time, in which case we will comply with your deletion request only after we
have fulfilled such requirements). When we delete any information, it will be
deleted from the active database, but may remain in our archives. We may
also retain your information for fraud or similar purposes.
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(f) This Privacy Policy may be updated from time to time for any reason.
We will notify you of any changes to our Privacy Policy by posting the new
Privacy Policy here CircleInApp.com/privacy and we will change the “Last
Updated” date above. You should consult this Privacy Policy regularly for any
changes.

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