"Circles" was designed to give you ownership and control of your contacts. Our Terms and Conditions and Privacy Policy have been designed to protect your data and be straightforward and easy to understand.
In summary:
- We never resell personal information about you or your contacts or share it unless necessary to provide the service.
- Your data belongs to you and you will always be able to delete your data from our systems.
- Protecting your information is our top priority and we take significant measures to keep it safe and secure.
This Privacy Policy describes how Circles may collect, use, store, and/or otherwise process personal data of the Users of the Circles Application.
Any processing undertaken in this context shall be in compliance with the provisions of the law, the jurisdiction of the state, and to the exclusive jurisdiction of the courts where Ibtikar al A’mal Ltd. has their registered offices - that is the Kingdom of Saudi Arabia.
This Privacy Policy does not concern the processing of the personal data of Third-Party Contacts of the Users which they provide when they use the Application. Circles and the User acknowledge and agree that with respect to the processing of such Third-Party Contact Data as defined below, the User is the Data Controller and Circles is a Data Processor acting pursuant to the terms of the relevant Circles Data Processing Agreement.
References in this policy to "we," "us," and "our" are references to Circles. References to "you" and "your" are to the Users.
Definitions
Application and/or Circles Application: The Circles phonebook manager application.
Circles and/or Ibtikar al A’mal Ltd.: Refers to Ibtikar al A’mal Ltd. a limited liability company registered under the laws of the Kingdom of Saudi Arabia with registration number 7009189437 which provides the hardware or software tool by which Personal Data are collected.
Personal Data (or Data): Any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified directly or indirectly in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
In the context of the services provided by Ibtikar al A’mal Ltd. via the Application, Personal Data refers to data relating solely to the User/Users as these are set out in the Types of Data Collected paragraph below.
Usage Data: Information collected automatically from Circles (or third-party service providers retained by Circles) as set out in detail in the Types of Data Collected paragraph below.
User/Users: The individual/s downloading and using the Circles Application.
User Data: Personal Data relating solely to the User as set out in the Types of Data Collected paragraph below.
Data Subject: The natural person to whom the Personal Data relates.
In the context of the services provided by Ibtikar al A’mal Ltd. via the Application, Data Subject refers to User/Users.
Data Processor (or Data Supervisor): The natural person, legal person, public administration, or any other body, association, or organization authorized by the Data Controller to process the Personal Data.
Data Controller: The natural person, legal person, public administration, or any other body, association, or organization with the right, also jointly with another Data Controller, to make decisions regarding the purposes and the methods of processing of Personal Data and the means used, including the security measures concerning the operation and use of Circles Application.
Cookie: Small piece of data stored in the User's device.
Third-Party Contact Data: Data other than User Data that are provided through the Circles Application functionalities by the User to Circles that concern persons other than the User and may include contact names, phone numbers, emails, and addresses.
Data Controller: With respect to the processing of personal data of the Users, Ibtikar al A’mal Ltd. acts as a Data Controller. Our contact details are set out below:
Ibtikar al A’mal Limited3394 Musa Ibn Nusair As Sulimaniyah 7261
Landline No.: +966 11 461 61 35
Fax No.: +966 11 461 61 27
P.O Box: 12241
Email: info@businesinnovation.com
Types of Data collected
Circles collects your Personal Data when you download the Application and you create an account with us or automatically when using the Application.
Circles may collect the following types of information relating to Users, which also include Personal Data:
- Full name and email address of a User: whenever a User communicates with Circles with an inquiry for support or for changing their subscription plan.
- User profile data: Information about the User such as name, contact details, country, address, profile photograph, and job information.
- Usage Data: Information collected automatically by Circles (or third-party service providers retained by Circles) which can include: the unique device identifier, the time of server requests, the method utilized to submit the request to the server, the size of the file received in response, the numerical code indicating the status of the server's answer (successful outcome, error, etc.), the features of the browser and the operating system utilized by the User, the various time details per visit (e.g. the time spent on each page within the Application) and the details about the path followed within the Application with special reference to the sequence of pages visited.
- Cookies: Use of cookies or other tracking tools by Circles or third-party service providers retained by Circles.
We use cookies or other tracking tools to provide and operate the Application. Failure to provide these cookies may make it impossible for us to provide the Application.
Apart from cookies which are strictly necessary for providing the Application and for which your consent is not required, we may also use cookies for improving our services, troubleshooting, as well as remembering your preferences for customization purposes. In such cases, we will request your explicit consent.
User Account Data: Anonymous information about the settings chosen by you and any plans or subscriptions you have purchased (no credit card details are held by Circles).
System Logs and Maintenance: For operation and maintenance purposes, Circles and any third-party service providers retained by Circles may collect files that record interaction with Circles (System Logs) or use for this purpose other Personal Data.
Users are responsible for any Personal Data of third parties obtained and/or published and confirm that they have the third party's consent to provide the Data to Circles.
Mode and place of processing the Data
Methods of processing
Data is processed in a proper manner and appropriate security measures are undertaken to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data.
The Data processing is carried out using computers and/or IT enabled tools, following organizational procedures and modes strictly related to the purposes indicated.
In addition to Circles, in some cases, the Data may be accessible to certain types of persons in charge involved with the operation of the site (administration, sales, marketing, legal, system administration) or external parties (such as third party technical service providers, mail carriers, hosting providers, IT companies, communications agencies) appointed if necessary as Processors or by potential purchasers or assignees of the Circles business.
We may share some of the Data with subsidiaries, joint ventures, or other companies under a common control ("Affiliates").
If another company acquires our company, business, or our assets, that company will possess the Data collected by us and will assume the rights and obligations regarding the Data as described in this Privacy Policy.
Place
The Data is processed at the operating offices of Circles and in any other places where the parties involved with the processing are located. For further information, please contact Ibtikar al A’mal Ltd.
Retention time
The Data is kept for the time necessary to provide the service requested by the User, or stated by the purposes outlined in this document, and the User can always request that Circles corrects, suspends or removes the data.
The legal bases for the use of the collected Data
The Data concerning you as a User is collected to allow Circles to provide its services via the Application.
We may also process your Personal Data where it is necessary for compliance with a legal obligation to which we are subject, for example if we are required by law to disclose certain Data to public authorities.
Finally, it may be necessary for us to process your Personal Data for the purposes of legitimate interests pursued by us and where such interests are overridden by the interests or fundamental rights and freedoms of Users. For example, your Personal Data may be used for legal purposes in Court proceedings or in the stages leading to possible legal action arising from improper use of the Application or the related services.
Detailed information on the processing of Personal Data
Personal Data is collected for the following purposes and using the following services:
Analytics
The services contained in this section enable Circles to monitor and analyze web traffic and can be used to keep track of User behavior.
Google Analytics (Google Inc)
Google Analytics is a web analysis service provided by Google Inc. ("Google"). Google utilizes the Data collected to track and examine the use of Circles, to prepare reports on its activities and share them with other Google services. Google may use the Data collected to contextualize and personalize the ads of its own advertising network. Personal Data collected: Cookie and Usage data.
Place of processing: USA - Privacy Policy.
Facebook (Facebook Inc)
Facebook is a service provided by Facebook Inc. used to track and examine the use of Circles and to prepare reports on its activities. Personal Data collected: Cookie and Usage data.
Place of processing: USA - Privacy Policy.
Contacting the User
Mailing List or Newsletter (Circles)
By registering on the mailing list or for the newsletter, the User's email address will be added to the contact list of those who may receive email messages containing information of commercial or promotional nature concerning Circles. Your email address might also be added to this list as a result of signing up to Circles Application or after making a purchase. To make things more convenient, we can also use phone number to contact users.
Furthermore, managing contacts and sending messages is handled by Cometchat, a third-party service.
Personal Data collected: Email address & phone numbers.
Hosting and backend as a service
These services have the purpose of hosting data and files that enable Circles Application to run and be distributed as well as to provide a ready-made infrastructure to run specific features or parts of Circles Application. The hosting with Circles takes place on secure cloud infrastructure. Some of these services work through geographically distributed servers, making it difficult to determine the actual location where the Personal Data are stored.
Microsoft Azure (Microsoft Corporation)
Microsoft Azure is a hosting service provided by Microsoft Corporation. Personal Data collected: Various types of Data as specified in the privacy policy of the service.
Place of processing: Europe - Privacy Policy.
Registration and authentication
Registering is made through phone number and email ID and is authenticated by utilizing OTP. Through registering & authentication, users allow Circles to identify them and give them access to dedicated services. Third parties may provide registration and authentication services depending on what is described below. In this case, Circles can access some data stored by these third-party services for registration or identification purposes.
Direct registration (Circles)
The User registers by filling out the registration form and providing the Personal Data directly to Circles.
Personal Data collected: Country, Email address, First Name, Last Name, Password, Phone number, and Picture.
Traffic optimization and distribution
These services allow Circles to distribute their content using a third-party CDN provider. These servers are located across different countries to optimize their performance. Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between Circles and the User's browser. Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information User are transferred.
Information not contained in this policy
More details concerning the collection or processing of Personal Data may be requested from Ibtikar al A’mal Ltd. at any time. Please see the contact information at the beginning of this document.
The rights of Users
You have the following legal rights with regard to the processing of your Personal data:
- the right of access to the personal data we hold about you
- the right to obtain rectification of any inaccurate personal data
- the right of erasure of your personal data
- the right of restriction of processing of your personal data
- the right to object to processing of your personal data
- the right to data portability
- the right to lodge a complaint with the relevant data protection supervisory authority in the Kingdom of Saudi Arabia
- Where the processing of any of your Personal Data is based on your consent, you may withdraw such consent at any time either by deleting your account or by contacting info@businesinnovation.com.
You may exercise your above rights by contacting us at info@businesinnovation.com.
Circles does not support "Do Not Track" requests.
To determine whether any of the third party services it uses honor the "Do Not Track" requests, please read their privacy policies.
Changes to this Privacy Policy
Ibtikar al A'mal Ltd. reserves the right to make changes to this Privacy Policy at any time by giving notice to its Users on this page and by way of an in-app pop-up notification. Therefore, it is strongly recommended to check this page often, referring to the date of the last modification listed at the top. If a User objects to any of the changes to the Policy, the User must cease using the "Circles" Application and can request that "Circles" removes the Personal Data. Unless stated otherwise, the then-current privacy policy applies to all Personal Data "Circles" has about Users.