circlr Privacy Policy
Effective date: January 2026
Organisation: Circlr Limited
Registered Office: Cavendish House, 18 Queen Street, St. Helier, Jersey, JE2 4WD
Jurisdiction: Jersey, Channel Islands
JOIC Registration Number: 70992
Last Updated: January 2026
1. Introduction
Circlr Limited ("circlr", "we", "us", or "our") is committed to protecting the privacy and personal data of individuals whose data we process. This Privacy Policy explains how we collect, use, disclose, and safeguard personal data in accordance with the Data Protection (Jersey) Law 2018 ("Jersey GDPR").
This Privacy Policy applies to:
- visitors to the circlr.io website;
- business customers and their authorised users of the circlr platform; and
- individuals who contact us in a business or professional capacity.
2. Our Role Under Data Protection Law
Depending on the context, circlr acts as either:
- Data Controller – where we determine the purposes and means of processing personal data (e.g. website operation, sales, marketing, billing, security, and support); or
- Data Processor – where we process personal data on behalf of our business customers in connection with the provision of the circlr platform.
Where circlr acts as a data processor, our processing activities are governed by our Data Protection Assessment (DPA) and customer contractual arrangements.
3. Categories of Personal Data We Process
circlr processes only limited personal data that is necessary to operate its website and provide the circlr platform to business customers.
This may include:
- basic business contact details (such as name, business email address, company and role);
- user account and authentication information;
- platform usage and audit data;
- customer-selected accounting and asset-related data processed on behalf of business customers.
circlr does not intentionally collect or process special category personal data (such as health, biometric, or other sensitive personal data).
4. Purposes and Lawful Bases for Processing
We process personal data for the following purposes and lawful bases:
| Purpose | Lawful Basis |
|---|---|
| Operating and securing the website | Legitimate interests |
| Providing the circlr platform and support | Performance of a contract |
| Customer administration and billing | Performance of a contract |
| Responding to enquiries | Legitimate interests |
| Marketing to business contacts | Legitimate interests or consent (where required) |
| Legal, regulatory, and compliance obligations | Legal obligation |
5. Cookies and Website Analytics
circlr uses cookies and similar technologies to operate and improve the circlr.io website. Cookies may be strictly necessary for site functionality or used for performance and analytics purposes.
Users are informed of cookie usage on first visit and may manage cookie preferences through their browser settings. Further information is provided in our Cookie Policy.
6. Data Sharing and Recipients
We may share personal data with:
- cloud hosting and infrastructure providers (e.g. Microsoft Azure);
- security, monitoring, and support service providers;
- professional advisers (legal, accounting);
- regulators or authorities where required by law.
Where circlr acts as a data processor, customer data is not shared except in accordance with customer instructions or legal obligations.
7. International Data Transfers
Personal data is primarily processed within the United Kingdom and Jersey. Where data is transferred outside these jurisdictions, appropriate safeguards are implemented in accordance with Jersey GDPR.
8. Data Retention
circlr retains personal data only for as long as necessary to fulfil the purposes for which it was collected, including legal, contractual, and operational requirements. Data is securely deleted or anonymised when no longer required.
9. Data Subject Rights
Individuals have the following rights under Jersey GDPR:
- right of access;
- right to rectification;
- right to erasure;
- right to restrict processing;
- right to data portability;
- right to object to processing; and
- rights relating to automated decision-making.
Requests may be submitted to the contact details below and will be handled within statutory timeframes.
10. Security Measures
circlr implements appropriate technical and organisational measures to protect personal data, including access controls, encryption, monitoring, and incident response procedures.
11. Complaints
Individuals have the right to lodge a complaint with the Jersey Office of the Information Commissioner (JOIC) if they believe their data protection rights have been infringed.
12. Changes to this Privacy Policy
We may update this Privacy Policy from time to time. The latest version will always be available on our website and will indicate the date of last update.
13. Contact Us
For questions about this Privacy Policy or our data protection practices, please contact support@circlr.io