SUMMARY

TheICircle aims to encourage educational and cultural exchange between people from all over the world and promote an open and inclusive approach. We are a community founded on respect for the cultural uniqueness of others and on trust. To earn that trust, we believe it is important to be clear and transparent about how we use your information and to protect your fundamental right to privacy.

This Privacy Policy describes how TheICircle,. and its affiliates (“we”, “us” or “TheICircle”) process personal data in connection with your use of the TheICircle Platform.

TheICircle collects and uses personally identifiable information (PII) that you submit;

TheICircle collects and uses this PII for the purpose of providing TheICircle services, including in-person educational programs, for marketing and communications in connection with such services, and to perform research;

For the purpose of providing its services, TheICircle may transfer this PII to TheICircle organizations and other parties involved in providing TheICircle services in your home country and other countries;

TheICircle transfers this PII across international borders to securely store this information in other countries.

You have the right to access and update your PII at any time;

In some circumstances you have the right to request that we erase your PII;

TheICircle may use (third party) cookies and other similar techniques to obtain information from you when using TheICircle websites in order to facilitate your use of these websites;

If you are a minor and your parent/legal guardian's consent is required to provide personal information, please ask your parent/legal guardian for permission.

PII includes, among other things, your name, your home and email addresses, your date of birth, your (mobile) telephone number, schools and universities attended, social media links , an image, photo or video of you, specific information about the TheICircle program (type, year, etc.), travel details, a personal statement, certain medical information and medical information, as well as answers to specific questions we may ask you based on the type of program you apply for or the services requested.

Please note that this is only a summary of the entire Privacy Policy to enable the reader to quickly understand the contents of this Privacy Policy. This summary does not replace the Privacy Policy.

We collect personal information from other sources, such as:

Third Party Services. If you connect, connect or access the TheICircle Platform with a third-party service (e.g. Google, Facebook, WeChat), you are instructing that tool to send us information such as, for example, registration data, friends list and contact information. profile of which the data controller is that service or as authorized by you through the privacy settings of that service.

Company Product Invitations and Account Management. Organizations that use our Company Products may submit personal information to facilitate account management and invitations to use the Company Products.

Guests and traveling companions. If you are invited to the TheICircle Platform, for example as a travel companion, the person who invited you may submit personal information about you such as your email address or other contact information.

Travel insurance for guests. If you have a claim under our Guest Travel Insurance policy, we will receive information about your claim in order to process, manage or assess the claim and as described in this Privacy Policy.

Other sources. To the extent permitted by applicable laws, we may receive additional information about you, including, for example, references, demographic data or information that helps detect fraud and security issues, from third-party service providers and/or partners, and combine it with the information we hold about you. For example, we may receive background check results or fraud alerts from identity verification service providers to use in our fraud prevention, security investigation and risk assessment efforts. We may receive information about you and your activities on or off the TheICircle Platform or about your experiences and interactions from our partners. We may receive health information, including, but not limited to, health information regarding contagious diseases.

HOW WE USE THE DATA WE COLLECT

Provide, improve and develop the TheICircle Platform. We may process this information to:

allow you to access the TheICircle Platform and make and receive payments,

allow you to communicate with other Members,

process your request,

perform analysis, debug and conduct research,

provide customer support, training,

send messages, updates, security alerts and account notifications,

process, manage or evaluate insurance claims or similar requests,

personalize and create a tailored experience, based on your interactions with the TheICircle Platform, your search and booking history, your profile information and preferences and other content you submit, and

allow the use of our company products and accommodation services.

If you provide us with information about your contacts, such as your friends or travel companions, we may process that information to: (i) facilitate sending invitations to other users, (ii) share details of your trip and facilitate travel planning, (iii) detect and prevent fraud, and (iv) facilitate the submission of your requests or for any other purpose authorized by you.

Create and maintain a reliable and safer environment. We may process this information to:

detect and prevent fraud, spam, abuse, safety and security incidents and other malicious activities,

study and combat discrimination consistently with our anti-discrimination policy,

carry out fraud prevention activities, security investigations and risk assessments,

verify or authenticate the information you provide,

cross-check databases and other sources of information, including background checks,

comply with our legal obligations, protect the health and well-being of our Guests, Hosts, Host employees and members of the public,

resolve disputes with our Members, including sharing information with your co-Host(s) or other Guests regarding disputes related to your role as a co-Host or additional Guest,

enforce our agreements with third parties,

determine eligibility for certain booking types, such as Instant Book,

comply with the law, respond to requests from public authorities, prevent harm and protect our rights

enforce our Terms and other policies (e.g. the Anti-Discrimination Policy), and

evaluate your interactions with the TheICircle Platform and information obtained from third parties. In limited cases, automatic processes that analyze your account and your activities on the TheICircle Platform, as well as information relating to activities on and off the TheICircle Platform that may be associated with you, may limit or suspend access to the TheICircle Platform if these processes reveal activities that are potentially risky to the security of TheICircle, our community or third parties. If you wish to dispute decisions based on automated processes, please contact us via the “Contact Information” section below. For more information on how our system determines whether certain bookings may pose a higher risk of incidents, please see this page.

Provide, personalize, measure and improve our advertising and marketing. We may process this information to:

send you promotional messages, marketing information, advertising, and other information that may be of interest to you based on your preferences, and advertising on social networks via the relevant platforms,

personalize, measure and improve our advertising,

administer invitation programs, rewards, surveys, sweepstakes, contests or other promotional activities or events sponsored or administered by TheICircle or its third-party partners,

analyze your characteristics and preferences to send you promotional messages, marketing information, advertising and other information that we believe may be of interest to you,

invite you to relevant events and opportunities, with your consent, send you promotional messages, marketing communications, advertising and other information that may be of interest to you based on your preferences.

Analysis and sharing of your communications.

We may review, scan or analyze your communications on the TheICircle Platform for the reasons described in the "How we use the data we collect" section of this policy, in particular for the purposes of fraud prevention, security investigations, risk assessment, compliance regulatory, investigation, product development, research, analysis, enforcement of our Terms of Service and customer support. For example, as part of our fraud prevention activities, we may scan and analyze messages to hide contact information and references to other sites, and, in compliance with applicable law, we scan and analyze all images uploaded by users to the platform TheICircle in conversations, profiles, ads and experiences for certain illegal or inappropriate activities (for example, evidence of child exploitation) for the purpose of identifying and reporting content violations to the relevant authorities. In some cases, we may also scan, review, or analyze messages to debug, improve, and expand product offerings. We will use automated methods when reasonably possible. However, we may occasionally need to manually review some communications, including, for example, for fraud and customer service investigations or to evaluate and improve the functionality of such automated tools. We will not review, observe, or analyze your messaging communications to send you third-party marketing messages, and we will not sell reviews or analytics of those communications. We may also share your communications as set forth in the “Sharing and Disclosure” section.

Providing Payment Services. Personal information is used to allow or authorize third parties to use the Payment Services, for example to:

detect and prevent money laundering activities, fraud, abuse and security incidents, as well as carry out risk assessments,

comply with legal and compliance obligations (such as anti-money laundering regulations and the imposition of sanctions),

enforce our Payment Terms and other payment policies, and

provide and improve the Payment Services.

OBJECTIVES AND PURPOSE

TheICircle (together with its TheICircle network organizations as defined below, collectively hereinafter referred to as “TheICircle”) is committed to protecting your privacy and safeguarding your personally identifiable information. TheICircle works hard to create an online experience that is detailed, efficient and productive by using the information you entrust to us responsibly. TheICircle is committed to respecting your privacy and adhering to the principles of data protection and privacy laws applicable throughout the world.

We have provided this Privacy Policy as an explanation of the information we collect, how we use it, how the use of this information can enhance your experience on our websites and during your relationship with us, with whom and for what purposes we may share information and the choices you can make regarding our use of information. We also describe the measures we take to protect the security of your information and how you can contact us about our privacy practices. Our privacy practices may vary between the countries in which we operate to reflect local practices and legal requirements. Each organization in the TheICircle network can supplement this document by sharing a local privacy policy. We want to help you make informed decisions, so please read the following sections carefully.

TheICircle ONLINE

TYPES OF INFORMATION WE COLLECT

PURPOSE OF COLLECTION, PROCESSING AND DISCLOSURE

CONSENT

DATA TRANSFERS ACROSS INTERNATIONAL BORDERS

ACCESS TO YOUR PERSONAL INFORMATION AND OTHER DATA SUBJECT RIGHTS

SAFETY SAFEGUARDS

POLICY ON ONLINE TECHNOLOGIES AND COOKIES

THIRD PARTY WEBSITES AND NETWORK WEBSITES

MINORS AND CHILDREN UNDER 13 YEARS

CONTACT US

UPDATES TO THE PRIVACY POLICY

TheICircle ONLINE

Through its website www.TheICircle.co, TheICircle may request and/or collect personally identifiable information, such as when you apply for or apply to a TheICircle program in person or online, in order to provide you with the information and services you seek or to improve your experience, as detailed below .

Some areas within our Website are intended for the general public, while some websites or areas within such sites are reserved only for organizations that are part of the TheICircle Hosting Network (and their authorized representatives) or for Specially designated and authorized third parties who work closely with TheICircle to administer Intercultural Study programs and to provide online and real-world services to individuals.

Likewise, certain areas within the Website are reserved for registered users only (for example, individuals who are potential, current or former participants in the services and programs offered by TheICircle and Network Organizations (“Participants”)).

It should be noted that Schools or Network Organizations are separate legal entities that are members of the international network of TheICircle organizations that operate TheICircle intercultural programs and activities worldwide according to the standard license, policies and procedures established by TheICircle including Participants are matched at various locations around the world to meet Participant requests and provide TheICircle study programs and services

For more information, see THIRD PARTY WEBSITES AND NETWORKING WEBSITES

TYPES OF INFORMATION WE COLLECT

TheICircle collects information from visitors and users of our Website and participants in our services, including Participants, and from third parties who collaborate with TheICircle to provide the TheICircle services so that we can provide an experience (online and offline) that aims to meet our Participants' and other users' needs and interests. Information may be collected as part of: (i) providing services to the TheICircle program, (ii) fulfilling requests for information, (iii) requesting or offering services, (iv) applying or registering for participation in the TheICircle program or TheICircle events , (v) submit an application or program opportunity request, (vi) respond to communications from us (for example, surveys, requests for additional information or reviews, or application or registration confirmations), (vii) accommodate your personal preferences, ( viii) fulfill requests for services, for example, signing up for newsletters or participation in promotions, grants or prizes, (ix) collaborating with third party sources, including collecting information available from certain social networks and other websites to help us better understand your interests and serve you better, (x) update your information, including contact information, (xi) keep you informed and involved in TheICircle activities

The types of personally identifiable information (sometimes called "PII") that we ask for and/or collect depend on your level of access and participation in our websites (and the types of services, information and participation you are seeking, such as apply for or participate in a TheICircle Tutoring or Hosting program or apply for a TheICircle program or other type of course or event). This information depends on the type of program or activity and the type of program you are applying for, as indicated in the respective application.

For our study abroad programs we need very detailed information to manage the program, including finding a host family and host school and offering travel medical insurance. In this case the information requested may include name, password, home address, work address and email address, telephone number, mobile number, geolocation information, date of birth, gender, schools and universities attended, links to social media Facebook, Twitter, Instagram and/or LinkedIn, an image, photo or video of you, your citizenship, passport information, visa status, insurance status, specific TheICircle program information (type, year, etc.), details about your trip, a personal statement, what languages ​​you speak, your current occupation and other relevant skills, some medical history and information, dietary restrictions, some usage data, such as test results, ratings, scores, progress, answers to specific questions and lifestyle information such as recreational activities and other information necessary to accommodate special requests (for example, health conditions that may require special accommodations or considerations in connection with a TheICircle intercultural program or study and accommodation activities at a Host).

To apply and participate in online programs, we may ask for your name, address and email address, telephone number, geolocation information, date of birth, gender, schools and universities attended, v, social media links to Facebook, Twitter , Instagram and/or LinkedIn, an image, photo or video of yourself, your citizenship, travel details, a personal statement, your CV or resume, which languages ​​you speak, your current profession and other relevant skills.

TheICircle may also collect other non-personally identifiable information about you, such as your use of our Website, communication preferences, aggregate data regarding your use of our services, and anonymous responses to questions and surveys.

Please note that to better safeguard your information, please do not include your credit card information in your electronic communication unless we specifically request it as part of the transaction fulfillment process on a TheICircle website.

PURPOSE OF COLLECTION, PROCESSING AND DISCLOSURE

Collection and use

TheICircle is committed to providing information about the collection and use of PII provided to or collected from visitors while using our Website, products and services. It is our policy not to ask you for information unless we need it or intend to use it. Some of the main purposes for requesting and collecting your PII are as follows:

provide our services (online and in the real world), such as responding to an inquiry or processing a request (for example, when Participants fill out an application, fulfill a request for information, or complete a request for services), arranging program placement ((e.g., select host families and schools), facilitate and manage a participant's involvement in a program, administer travel medical insurance, and collaborate with network organizations, sponsors and service providers to this end

marketing and communications with you in relation to the services offered by TheICircle and other trusted third parties,

carry out research through surveys, questionnaires and reviews to better meet your needs, improve the effectiveness of our Website, your experience, our various types of communications, campaigns and/or promotional activities

alumni engagement and other outreach activities, to keep you informed and involved in TheICircle activities (such as campaigns, conferences, publications, recruitment of host families and volunteers, new programs and services).

We retain your PII for periods reasonably necessary to provide our services and outreach. We ask for your consent to send you marketing communications. You can opt-out of our TheICircle emails, newsletters and surveys and reviews at any time by clicking the link included in such communications or by contacting us directly to unsubscribe. You will always be given the option not to submit your PII or to decide what communications you wish to receive from us. However, this may compromise some transactions. For example, failure to provide requested information such as your name will prevent a request from being processed.

Processing and dissemination

In most cases, the information you provide is added to a local or global TheICircle database. As a general practice, TheICircle does not sell, rent, or grant physical possession of your PII to any unaffiliated third parties other than relevant and applicable network organizations and service providers (including third party organizations with which TheICircle partners to provide the its programs) that you need to know to perform services and requests initiated by you or by TheICircle to provide you with TheICircle services. For example, we may provide access (via a TheICircle website) or transfer PII to certain relevant network organizations that need to receive such information in connection with a home and school placement for a TheICircle program. We work hard to ensure that these third parties only share this information with other organizations or individuals who partner with them to operate TheICircle-related programs or provide other TheICircle services. In the course of obtaining TheICircle-related services, it may happen that you end up sending personal information directly to a network organization or to a third-party organization, such as online platforms used to provide online program content, in which case you should read and accept their privacy policies as required by those entities before submitting your personal information.

For in-person program participants, TheICircle will access and use the information and documents shared as part of the program application or produced during program participation for the following purposes:

(a) Manage travel medical insurance purchased as part of the program services. TheICircle, your insurer and other parties involved in providing your medical plan services will use your medical data to the extent necessary to administer your plan and process medical claims.

(b) Evaluate whether a program participant is and remains eligible for the program. This is necessary for TheICircle to determine whether a medical condition, at the time of application, or arising during participation in the programme, is compatible with the safe initiation and continuation of the exchange program in the host country, or whether the repatriation of a participant to return participant to the care of parents/legal guardians to appropriately manage relevant medical issues. Staff from the hosting and sending organizations will have access to medical records only on a need-to-know basis.

In addition, other situations in which TheICircle may disclose your information to affiliated organizations, service providers include:

when we have received your consent to do so

in situations where sharing or disclosing your information is necessary to provide you with the services you desire or when companies or service providers conducting business on behalf of TheICircle request such information (for example, credit card processing, customer support, market research administration or database management services)

in the event that TheICircle is merged or acquired by another company

to comply with legal or regulatory requirements or obligations under applicable law, court order, or subpoena

In the event of an emergency involving the protection of life, health or property of an individual

If information is shared as mentioned above, we try to limit the recipients and scope of the information provided to only the amount necessary to perform the specific function.

Unless otherwise prohibited by legal process, we require third parties to protect your PII and to comply with applicable privacy laws and regulations.

We sometimes use and share non-personally identifiable information that we collect to maintain the services we offer online, improve the design and content of our sites, to allow us to personalize your experience, analyze trends, gather broad demographic information, conduct research, administer sites and strengthen our marketing and branding efforts.

SHARING AND DISCLOSURE

If you are located outside the United States, please find out about the safeguards we rely on when transferring personal information to recipients outside the EEA here.

Sharing with your consent or at your direction.

Where you have given your consent, we may share your data as described at the time we have obtained your consent, for example when you authorize a third party application or website to access your TheICircle account, or when you participate in promotional activities conducted by TheICircle partners or third parties.

Where permitted under applicable law, we may use certain information about you, such as your email address, that we share with social media platforms after anonymizing it, to generate leads, drive traffic to TheICircle, or otherwise promote our products and services.

Sharing between Members.

To facilitate bookings or other interactions between Members (who may be located in or use service providers located in jurisdictions with different levels of data protection), we may share information in situations such as:

Between Guest and Host, when:

A booking request is made, when a co-host is present or a dispute is submitted, including profile, name, names of any additional Guests, cancellation history, review information, age of the guest (unless prohibited by applicable law ), outcome of the dispute (if applicable), and other information you choose to share and submit.

A reservation is confirmed, additional information is disclosed to facilitate travel coordination, such as your phone number and profile photo.

As a Host you have a confirmed booking, some data will be shared with the Guest (and any additional Guests invited, if applicable) to manage the booking, including, for example, your profile, first and last name, telephone number and address of the Accommodation.

You communicate with a Member, such as your name, profile picture and message content.

Among the Guests when:

As a Guest, you invite additional Guests to a booking, your name, travel dates, Host name, Listing details, Accommodation address and other relevant information will be shared with each additional Guest.

Between Hosts when:

you accept an invitation to become a Co-Host with another Member, you authorize these other Members, such as Co-Hosts, to access and update your data and Member Content, such as certain information such as your first and last name, telephone number, Accommodation address, calendar, Listing information, Listing photo and email address.

Information you post on Profiles, Advertisements and other public information.

You can make certain information visible to the public, such as:

Your public profile page, which includes your profile photo, name (or initials where applicable), description, and city.

Listing pages that include information such as a description of the approximate or precise location of the Accommodation or Experience, calendar availability, profile photo, aggregate demand information (e.g. the number of views in a given period ) and any additional information you choose to share.

Reviews, ratings, and other public feedback.

Content in a community or discussion forum, blog, or social media posting.

We may display portions of your public profile and other Content you make publicly available, such as your Listing details, on third-party sites, platforms, and apps.

Data shared publicly by you on the TheICircle Platform may be indexed by third-party search engines. In some cases, you can disable (opt-out) this feature in your account settings.

Compliance with the law, responding to requests from public authorities, preventing harm and protecting our rights.

We may disclose your information to law enforcement, law enforcement or governmental or public authorities, to tax authorities, or to authorized third parties, or to other Members, if and to the extent that we are required or authorized to do so by law or if such disclosure is reasonably necessary: ​​(i) to comply with our legal obligations, (ii) to comply with a valid legal request (such as a subpoena or court order) or to respond to claims made against TheICircle, (iii) to respond to a valid legal request relating to a criminal investigation or alleged or suspected unlawful activity, or to respond to or address any other activity that may expose us, yourself, or any of our users to liability under any law or regulations (for more information on the TheICircle Law Enforcement Guidelines, please see this link), (iv) to administer and enforce our agreements with Members, including our Terms, Additional Legal Terms, and Policies, or (v) to protect the rights, property, or personal safety of TheICircle, its employees, its Members, or the public at large.

Where appropriate, we may notify Members about law enforcement requests, unless: (i) providing such information is prohibited by applicable legal process, by order of a court or by law, or ( ii) we believe the notice is unnecessary or ineffective, creates a risk of injury or physical harm to an individual or group of individuals, or creates or increases a risk of fraud against TheICircle, its Members, or exposes TheICircle to charges of obstruction of justice.

Where required or permitted by applicable law, we may disclose Host and/or Guest data to tax authorities or other public bodies for the purposes of tax authorities' determination of compliance with relevant tax obligations. Relevant tax obligations include TheICircle' tax obligations relating to its service charges, tax obligations arising from its facilitation of accommodation taxes and withholdings, and Hosts' individual tax obligations. Information that may be disclosed includes, but is not limited to, Host and Guest names, listing addresses, Host addresses, tax/corporate identification numbers, date of birth and/or information contact details, the cadastral identification data of the property, information on compensation, dates and amounts of transactions, the number of nights and guests booked, the gross and net value of reservations and the amounts of compensation, taxes collected by TheICircle on behalf of Guests and Hosts, to the extent such information is known to TheICircle.

In countries where TheICircle facilitates or requires a Host's application or registration, notification, permit or license number with a government authority, we may share information about participating Hosts - such as the Host's first name, last name and contact details, Accommodation address, tax identification numbers, registration number, permit or license, Listing details, booking information and number of nights booked - with the relevant authority, both during the application process, at the time of publication of the 'Announcement, which, subsequently, at periodic intervals of time, in compliance with applicable laws.

5. OTHER IMPORTANT INFORMATION

5.1 Third Party Partners and Integrations.

Parts of TheICircle may be linked to third-party services. TheICircle does not own or control such third parties. When you interact with them and choose to use their service, you are providing them with your information. Your use of these services is subject to the privacy policies of those providers, including the Google Maps/Earth Additional Terms of Use, the Google Privacy Policy (see this page for more information on how Google uses information), the PayPal Privacy Statement, the Citi Privacy Policy, and the Stripe Privacy Policy.

CONSENT

Where consent is the legal basis for TheICircle' processing of your PII, we will also ask you to acknowledge your consent and your consent to TheICircle' processing of your data under the terms of this Privacy Policy, e.g. , requiring you to sign a separate agreement, clicking "I accept" on an online page, accepting this Privacy Policy, or taking other affirmative action before you can use or access certain websites or portions of our Website. Additionally, as part of our commitment to keeping you informed, we may ask for your consent to use your contact information to keep you informed about TheICircle services or upcoming opportunities, events, enhancements, TheICircle campaigns or other relevant information that may be of interest to you .

You may also receive communications from third party service providers who provide services to TheICircle, which will be subject to the privacy policies and consent requirements of such third parties. You can always unsubscribe from TheICircle marketing communications by following the directions included in our emails or other communications, or by contacting TheICircle directly.

If you are a minor and your parent/legal guardian's consent is also required, please ask your parent/legal guardian for permission before sharing your PII with us. In this case TheICircle may also contact (for example via email) your parents or legal guardians to confirm their consent.

TheICircle may also process your PII without consent as a lawful basis, such as when necessary to fulfill certain transactions and services you request.

DATA TRANSFERS ACROSS INTERNATIONAL BORDERS

As a global organization, we are committed to providing our services wherever you are. To achieve this we may use cloud services provided by Amazon Web Services, using data centers located in the United States or other countries around the world. These databases are restricted in access and may only be accessed by TheICircle employees, consultants, service providers and volunteers, who will use the information solely for TheICircle business and managing TheICircle program operations. The nature of our business and operations requires us to process and transfer your information, including personal information, to network organizations, third party organizations and data centers or service providers that may be located in countries outside of your . We may process and transfer the PII we collect about you in and to countries other than the country in which the information was originally collected, including to the country of a network organization that may enroll you in a TheICircle program and by sending your PII to TheICircle in seeking such services or information, you consent to such transfer and processing.

Although the data protection and other laws of these various countries may not be as comprehensive as those in your country, TheICircle will take appropriate measures to protect your PII in accordance with this Privacy Policy and applicable laws.

ACCESS TO PERSONALLY IDENTIFIABLE INFORMATION AND OTHER RIGHTS OF THE INTERESTED PARTY

The European Union's General Data Protection Regulation and the privacy laws of other countries grant certain rights to data subjects.

If you would like to confirm that we are processing your PII or have access to PII we may have about you, please contact us. You can also request access to your PII or information about: the purpose of the processing; the categories of data concerned; who else outside of TheICircle may have received data from TheICircle; what the source of the information was (if you did not provide it directly to TheICircle); and how long it will be stored. You have the right to correct (rectify) the record of your PII maintained by TheICircle if it is inaccurate. You can request that TheICircle delete such data or stop processing it, subject to certain exceptions. You can also request that TheICircle stops using your data for direct marketing purposes. In many countries, you have the right to lodge a complaint with the relevant data protection authority if you have concerns about how TheICircle processes your personal data.

To ensure that your PII is accurate and up-to-date, we encourage you to regularly review and update your information as necessary. You can review and update your information online or by contacting us. We may also contact you to ask you to update your information. Please note that, in an effort to prevent unauthorized disclosure of your PII, you may be asked to provide proof of identity (or other authentication material). Access to PII cannot be provided over the telephone. If, after review, you wish to deactivate or delete a profile or application, or update your PII, we will endeavor to do so without undue delay. Occasionally, information that you request deletion will be kept in certain files for a period of time as part of our legal retention. Additionally, some types of information may be stored longer or indefinitely on “backup” systems or within log files due to technical constraints or financial or legal requirements. Therefore, you should not always expect all of your PII to be immediately removed from our databases in response to your request.

Please refer to the appropriate contact information below to contact us if you have any questions about our privacy practices or would like to submit a request.

SAFETY SAFEGUARDS

TheICircle recognizes the importance of information security and constantly reviews and improves our technical, physical and logistical security rules and procedures. All websites and servers owned by TheICircle have security measures in place to protect your PII from accidental, loss, misuse, illegal or unauthorized access, disclosure or alteration while it is under our control. While “guaranteed security” does not exist on or off the Internet, we safeguard your information by using appropriate administrative, procedural, and technical safeguards, including password controls and the use of Secure Sockets Layer (SSL), an encryption method used to protect data from interception and hacker attacks during transit. Access to data stored in the systems is subject to authentication with a unique username and password. Users can only access information that belongs to their area of ​​expertise. Online confidentiality agreements are in place, for example as click-through consents, to be accepted upon first access and then annually, to ensure that certain users who have access to selected data are bound by appropriate confidentiality obligations.

POLICY ON ONLINE TECHNOLOGIES AND COOKIES

Please see the separate Online Technologies and Cookies Policy.

To know more!

THIRD PARTY WEBSITES AND NETWORK WEBSITES

To anticipate your needs, TheICircle may provide links to non-TheICircle websites for your convenience and information. TheICircle is not responsible for any content presented or contained on any independent website, including, but not limited to, any advertising claims or marketing practices.

Please be aware that although TheICircle protects your information on websites owned and operated by TheICircle, we cannot control and will not be responsible for the privacy policies of third-party websites, including websites owned or controlled by independent third parties. Third-party websites that you access through links on our Websites have separate privacy practices, data collection practices and security measures. We have no responsibility for the practices, policies and security measures implemented by third parties on their websites. We encourage you to contact them to ask questions about their privacy practices, policies and security measures before disclosing any PII. We recommend that you review the privacy statements and policies of linked websites to understand how those websites collect, use and store information.

Network Organizations are directly responsible for the content presented or contained on their respective national TheICircle websites. While this Privacy Policy informs you of how we collect, use, share and store your information in connection with all TheICircle sites, privacy practices privacy may vary between the countries in which TheICircle operates to reflect local practices and legal requirements. Accordingly, the national websites of Network Organizations may display additional privacy notices applicable to those websites. When you access Network Organizations' websites, please carefully review any additional privacy notices and policies on those sites and contact those Network Organizations directly if you have any questions.

SERVICE PROVIDERS.*

We share personal information with affiliated and unaffiliated service providers (including their service providers) to help us manage our business and for their compliance purposes, including service providers who help us: (i) verify the your identity or identification documents, (ii) verify information against public databases, (iii) conduct criminal background checks, fraud prevention, security investigations and risk assessments (iv) provide product development services , maintenance and technical assistance, (v) allow the provision of TheICircle Services through third-party platforms and software (for example through integration with our API), (vi) provide customer support, advertising or payment services, (vii) offer additional services chosen by you, (viii) process, manage or evaluate compensation claims or other requests of a similar nature, or (ix) examine, scan and analyze communications on the TheICircle Platform for certain purposes (such as obtaining evidence of child exploitation) . For more information, see Analyze and share your communications. These providers are contractually bound to protect your personal information, to which they have access to perform these activities. Other Members may use services other than TheICircle to process your data. These may include email or reservation management software. Such services are outside the control of TheICircle and will be subject to applicable laws around the world with varying levels of data protection.

MINORS AND CHILDREN UNDER 13 YEARS

TheICircle does not seek to obtain nor does it wish to receive personal information directly from children under the age of 13; and we cannot always determine the age of individuals who access and use our websites. If we discover that we have done so inadvertently, we will immediately delete such information. Additionally, if we discover that a minor (as defined by applicable law) is providing us with information without parental or guardian consent when requested, we will remove this information unless the parent/guardian approves the provision of such information.

BUSINESS TRANSFERS.

If TheICircle enters into or becomes involved in any merger, acquisition, reorganization, divestiture, or bankruptcy or insolvency proceeding, it may sell, transfer or share some or all of its assets, including your data, in connection with or as a result of any such transaction (e.g. during the due diligence phase). In this case, we will notify you before your personal information is transferred and becomes subject to a different privacy policy.

CONTACT US

If you have any questions about this policy or our privacy practices, or if you would like to submit a request, you can contact us as follows:

NEWW S.r.l.

V.A.T: 13006211000

by e-mail to the address: contact@TheICircle.co or by writing to us at:

Via di Pietralata 157, 00158 Rome, TheICircle

Attention: TheICircle Legal Department

Furthermore, you can contact TheICircle' data protection officer at: contact@TheICircle.co. Tel: ( + 39 ) 06 94329890

UPDATES TO THE PRIVACY POLICY

TheICircle may modify this Privacy Policy from time to time in order to meet changes in the regulatory environment, business needs or to meet the needs of our visitors, participants, network organizations, affiliates, strategic partners and service providers. Updated versions will be posted on our websites and will be date stamped so you are always aware of when the Privacy Policy was last updated.