Circular Global Ledgers SA ("we", "our", or "us") is committed to safeguarding your privacy. This Privacy Policy ("Policy") outlines how we gather, utilize, and disclose personal information collected from individuals who use our website www.saturnwallet.xyz, mobile apps, and browser extensions (collectively, the "Services"), including any features or tools accessible through these Services. It also explains how we handle the information we gather.

By using our Services, you agree to this Policy (as it may be updated from time to time), alongside our Terms of Service, which govern any disputes related to privacy and include limitations on liability and dispute resolution procedures.

Overview

• Protecting your privacy is a fundamental value at Circular, and we take necessary measures to ensure user data is handled responsibly. We strive for transparency in how we manage any information we collect.

• You do not need to provide personally identifiable information like your name, email address, or phone number to use our Services.

• We do not use your IP address for advertising or marketing purposes, and we ensure that your IP is not connected to identifiable details such as your wallet address or username.

• We also provide users with the option to opt out of our analytics tools for enhanced privacy.

• This Policy will be revised if there are any significant changes to our privacy practices or relevant laws.

Information We Collect

We gather information about you both directly and automatically, as well as from third-party sources.

Information You Provide to Us

You can use our Services without registering or submitting personal details. However, certain data is collected when you interact with our Services, such as:

• A username that you select for your account, along with any images or media you upload for creating collectibles.

• Your email address or other contact details, as well as any other information you provide through surveys, support queries, promotional activities, or email sign-ups.

Automatically Collected Information

We automatically collect data related to your usage of our Services, including:

• Technical details like your device model, browser type, operating system, and unique device identifiers.

• Your IP address, which we temporarily store to:

  • Secure our Services and guard against DDoS attacks.

  • Estimate your general location (e.g., country or state).

  • Facilitate the necessary network connection between your device and our Services.

  • Comply with legal requirements, such as adhering to sanctions.

• Publicly available data like your wallet address or public blockchain data, used strictly to enhance and provide our Services, as well as for legal purposes.

We do not use IP addresses for advertising purposes or link them with any personal identifiers such as your username or email.

Data from Other Sources

If you log into our Services through a third-party platform (e.g., Google), we may access certain data from that platform (like your email address), depending on the permissions you grant.

How We Use Your Information

We use the data we collect for the following purposes:

To Provide Our Services

We use your information to operate and enhance our Services, communicate with you about your use of our platform, and respond to your inquiries.

To Personalize Your Experience

We may use your information to offer personalized content, recommend services, and provide location-based customization or support.

To Improve and Develop Our Services

Your data helps us understand how our Services are used, allowing us to optimize functionality, make improvements, and develop new features.

For Marketing and Communication

We may use your information to send promotional emails, newsletters, or special offers. If you enter a contest or promotion, we may also contact you for marketing purposes.

For Legal and Security Purposes

We may process your data to comply with legal obligations, address fraud, enforce terms of service, respond to law enforcement or regulatory inquiries, or protect the rights and safety of our users and ourselves.

How We Share Your Information

We may share your information in the following situations:

• With Your Consent: If you provide explicit consent, we will disclose your data as per your authorization.

• Affiliates: We may share data within our corporate group of companies.

• Vendors and Service Providers: We may share information with third-party partners who assist us with tasks such as customer support, analytics, and marketing.

• Business Transfers: If our company is involved in a merger, acquisition, or asset transfer, your information may be transferred to the new entity.

• Legal Compliance: We may disclose your data in response to legal requests, including court orders or government inquiries.

• To Protect Legal Rights: If necessary, we may disclose data to prevent illegal activities, fraud, or potential harm to individuals or our business operations.

• Aggregate or De-Identified Data: We may share aggregated or anonymized data for research, marketing, or analytical purposes.

We will not sell your personal data to third parties for marketing purposes.

Cookies and Tracking Technologies

We use cookies and similar tracking technologies to collect information about how you interact with our Services.

• Cookies: These small data files are placed on your device to help us remember user preferences, improve performance, and track site activity.

  • Session Cookies are temporary and deleted after your browser session ends.

  • Persistent Cookies remain on your device even after you close the browser and are used to track long-term user behavior.

You can manage cookie settings through your browser, but disabling cookies may affect your ability to use certain features of our Services.

• Third-Party Analytics: We use third-party analytics tools to assess how users engage with our platform and identify areas for improvement.

Third-Party Links

Our Services may contain links to external websites, which are not governed by this Policy. We are not responsible for the privacy practices of these external sites.

Your Rights and Choices

Access and Control Over Your Information

You may request access to, or a modification or deletion of, the personal information we have collected about you by contacting us at info@circularlabs.io. We will respond to such requests in accordance with applicable laws, though certain data may need to be retained for legal or business purposes.

Marketing Communications

You can opt out of receiving marketing emails from us by following the instructions in the emails we send. Please allow up to 10 business days for us to process your request.

Contact Us

If you have any questions about our privacy practices or wish to file a complaint, please contact us at info@circularlabs.io.

Changes to this Policy

We may update this Privacy Policy periodically. When we make significant changes, we will notify you by revising the date at the top of the Policy or by sending a direct notice. We encourage you to review this document regularly to stay informed about our privacy practices.

Additional Information for Residents of Specific Jurisdictions

For U.S. Residents

Certain U.S. states, including California and Colorado, have privacy laws that provide additional
rights. This section applies to individuals residing in those states.

For EU Residents

If you're located in Europe, this section contains relevant information about how your personal data is processed in accordance with EU law.

For Canadian Residents

If you reside in Canada, this section explains how we handle your personal information in compliance with Canadian privacy laws.

By providing your personal information to Circular or our service providers and agents, you agree to the collection, use, sharing, and transfer of your data as outlined in this Policy and as required or allowed by law.

You have the right to withdraw your consent at any time regarding the collection, use, sharing, or transfer of your personal information. To do so, please contact Circular at info@circularlabs.io. Please note that if you withdraw your consent (or choose not to provide certain personal details), you understand that Circular may no longer be able to offer certain products, services, or information that could be useful to you.

We retain personal information only for as long as it is needed to fulfill the purposes for which it was originally collected, as well as for other legitimate business purposes outlined in this Policy.