SmallCircle = Privacy

“Privacy is a birthright. Privacy is in the DNA of SmallCircle.”

As an end-user on SmallCircle you can interact with your friends as contacts and with businesses. SmallCircle doesn’t just protect users privacy and data, it puts users in control, in the drivers seat of their privacy and data.

Learn how we, “SmallCircle”, live up to our values in this privacy notice. This privacy notice applies to all platforms incl. websites and applications owned by SmallCircle B.V., “SmallCircle”, “SmallCircle Chat”, “joinsmallcircle.com” with its principal place of business in Amsterdam, The Netherlands.

Joining SmallCircle

SmallCircle collects your mobile phone number to send you the OTP (one-time-password code) by SMS allowing you to securely login.

• When users do not open the SmallCircle applications for 52 consecutive weeks, then our servers will automatically remove your mobile phone number along with any records associated.

To protect user mobile numbers while using the App, SmallCircle immediately assigns users a random unique QR-code and anonymous id.

Protecting Your Privacy, Protecting you from Phishing and Other Unwanted Messages on SmallCircle

To add contacts, users are not required to share mobile numbers with other users. Users can send friend requests by scanning other users QR-codes.

Users hold the power to accept friend requests, or anonymously reject friend requests.

When a user removes a contact, the removed contact will no longer be able to contact the user through the applications.

If non-contact users have your mobile number in their mobile phone address book or your QR-code from other sources, the other non-contact users will not be able to contact you without your acceptance of a friend request within the application.

Users are able to block future friend requests from specific users when removing those users as a contact.

SmallCircle does NOT

• analyze at what time of the day a specific user chats or actively chats
• analyze how frequently a specific user chats in a day or period of time
• analyze how many or which specific contacts a specific user adds or chats with
• create anonymous shadow profiles to analyze a specific users chat behavior

SmallCircle simply is not interested in your chatting and personal App usage behavior, or personal information, the business model is not to sell, or lease your data to 3^rd parties.

SmallCircle does

• analyze the total count of App opens in a period of time
• analyze the total count of chats in a period of time

SmallCircle analyzes the total count information to simply measure and report the popularity of the applications.

Furthermore, SmallCircle uses the total count information to monitor the need to scale-up or scale-down servers for specific periods of time to maintain stability and performance.

We do not sell, or lease the total count information to 3^rd parties.

When users send messages in a group chat or to individual users, SmallCircle:

1. encrypts messages
2. delivers messages
3. provides option to users to report any messages in violation of the ToS

SmallCircle will comply with local governments and regulations when required by law enforcement and rulings, such as court orders, and we strongly condemn any unlawful activity on our platforms.

Following removal of messages from SmallCircle servers, delivered messages are stored only on the sending and receiving users’ local devices.

Voice & Video Call

Voice and video call are heavy bandwidth activities.

SmallCircle does collect activity data and analyze aggregated bandwidth, aggregated call minutes compared with the time of the day to (pro-)actively scale up or scale down call servers.

SmallCircle does NOT

• analyze individually identifiable user voice and video call activity data
• sell, or lease voice and video call activity data to any 3^rd parties

Business Channel Privacy Notice

When business owners or managers create business channels on SmallCircle, they are required to submit personal information and public information such as but not limited to:

• Day-to-day Business Name (required)
• Mobile Phone Number (required)

SmallCircle or its Service Providers collect, analyze, process and use such information to personalize marketing and other services to businesses and verify the authenticity of businesses.

When businesses on-board “business channel clerks” to provide standard services to users, such as but not limited to 1:1 Client chats, In-Channel Support communication or Loyalty & Rewards services businesses are required to enter the Clerk’s personal information:

• Mobile Phone Number (required)

SmallCircle processes business channel clerk’s personal information to make essential business channel functionalities available and enhance services to business channel clerks, such as but not limited to interacting and communicating promotional activities with 1:1 Clients, in-channel chat support, rewarding clients participating in the business channel loyalty & rewards program, managing 1:1 Clients data or executing tasks on behalf of the business channel.

Interacting with Business Channels on SmallCircle

When users interact with “business channels or business channel clerks” (hereinafter businesses), the user may opt-in to share data with businesses to access specific business channel services, support and products.

When users join a business channel, the business channel requires to collect minimum personal information and consent from users to function well and for marketing and promotion purposes:

• mobile phone number (required)
• nickname (required)

The user is able to control the shared personal information/data and consent through the privacy page and can change or remove the shared data, and opt-out consent per business at any time.

Accessing business channel services

For further use of business channel services, the data types that businesses may request users to share depend on the nature of the business service that the user is trying to access and are requested at the discretion of the business.

When businesses request data, the users are given the explicit choice to opt-in or opt-out sharing specific data with businesses depending on the requirements set by the businesses to access specific business services.

To access certain business services, businesses may request additional data from users to enhance or personalize their service.

When a business requests users to share data, specific required and optional fields will be listed out to the user, in the order of a form, of which the fields users can choose to fill in for their specific purposes.

When users consent on sharing data with specific businesses for specific purposes, only the entered information will be shared with the business.

When users interact through chat communication with businesses, users consent to businesses collecting and analyzing

• business chat service records; business in-channel support service chat records (required)
• business chat service records; business clerk 1:1 client service chat records (required)

Businesses on SmallCircle may

• analyze, process or use the user shared data and business chat service records to offer better service, personalize marketing, product, event and service promotions or extract such information depending on user consent

SmallCircle does

• process, analyze, encrypt, store and structure shared data and business service records for businesses
• process and analyze total count of business interactions and types of interactions

The purpose of analyzing the data and information is to suggest businesses and empower clerks with enhanced suggested content for communication with their consenting business channel users (1:1 clients), and support business decision making processes in regards with but not limited to validating loyalty & rewards transactions.

SmallCircle does NOT

• own the shared data or business service records that users consent to sharing with businesses when interacting with business channels
• sell, or lease the shared data or business service records to 3^rd parties or to other businesses active on SmallCircle for any purpose

Users can control the data they’ve shared with businesses in real-time exercise their right to be forgotten

On the user’s privacy page, users can view the list of all businesses that user’s have shared data with.

Users can tap on the businesses in the list on the privacy page to see the specific types of data, related information and for what business service or purpose the specific data was previously shared.

SmallCircle empowers users to view, control, make changes, manage consent, opt-out and remove shared data at anytime.

In SmallCircle the user is in charge of their personal data owned by businesses.

 

Why would businesses appreciate the extent of access for users to control their data?

SmallCircle cherishes privacy, its in our DNA, and we foresee that in future other businesses will follow our lead.

In fact, we see the power for consumers to remove data from businesses as a win-win.

We envision that users who don’t require services from a business simply aren’t interesting customers for the business and vice versa. Therefore, businesses not need spend effort to pursue such customers.

Businesses in turn can focus their efforts on customers who are comfortable with sharing their data with such business.

Secure Data Vault

Whilst users share their data with businesses, users have the option to save their personal data in SmallCircle’s Secure Data Vault.

SmallCircle offers the Secure Data Vault to users for conveniently sharing with businesses while interacting and accessing services.

SmallCircle does NOT

• own the data saved into the secure data vault
• analyze the data saved into the secure data vault
• create anonymous shadow profiles based on data in the secure data vault
• sell, or lease the data to 3^rd parties from the user’s secure data vault

SmallCircle does

• process and store data in the secure data vault in a structured manner for when users opt-in to make use of the secure data vault
• share the data with businesses when and if users opt-in to make use of the data
• encrypt data in the secure data vault

Tracking, Cookies and Advertising on Web and iOS Devices

This part of notice only applies to Web or iOS (Apple) device end-users. We use Apple’s official App Analytics tools under Apple Developer Program License Agreement (refer to Section 6.7), as available on (https://developer.apple.com/support/terms/).

We do not use cookies or other 3^rd party tracking tools such as Google Analytics to track your user behavior on our website or within iOS devices.

Therefore for iOS device users please refer to the official Apple website for:

• Apple App Store Privacy Details (https://developer.apple.com/app-store/app-privacy-details/)
• Apple’s Privacy Policy (https://www.apple.com/legal/privacy/en-ww/)

Tracking, Cookies and Advertising on Android Devices

This part of notice only applies to non-iOS (non Apple device) end-users. SmallCircle utilizes Google Firebase Cloud Messaging (FCM) and thus the Firebase SDK to send notifications to users on Android devices.

SmallCircle does NOT utilize Google Analytics for Firebase.

Therefore for Android device users please refer to the Firebase SDK privacy policy for further information (https://firebase.google.com/support/privacy).

Use of Service Providers

SmallCircle may use Service Providers to assist us in processing and analyzing data on our behalf.

The Service Providers are in any case not permitted to use data for any other purpose or disclose it to any other party than for what SmallCircle does as mentioned in this Privacy Policy.

If SmallCircle does not collect user behavior and usage metadata, then how does SmallCircle improve the App?

SmallCircle does not rely on any 3^rd party services. SmallCircle cherishes privacy. SmallCircle works with the best “product minds” in the world.

The team uses SmallCircle on daily basis and whilst using the App, the team thinks about what can be done better.

Users may also submit their feedback by contacting our team directly for improvement suggestions as well as inquire on privacy details on hello@joinsmallcircle.com. We listen to you.