Privacy Policy

YOUR PRIVACY IS IMPORTANT TO US

This privacy notice (“Privacy Notice”) explains how Smart Circle International, LLC and its parent entities, sister companies, and other entities that are related to Smart Circle by common ownership (“Smart Circle,” “us,” “we” or “our”) collects, uses, discloses, and otherwise process personal information (defined below) in connection with our websites (the “Sites”) and other websites and applications we own and operate that link to this Privacy Notice, and the related content, platforms, services, products, or other functionality offered on or through our services in person, by phone, or other offline methods (collectively, the “Services”).

This Privacy Notice applies to individuals (“you” or “your”) who visit our Sites or have a business relationship with Smart Circle, such as clients and retailers or other venue providers, in their business interactions with Smart Circle. This Privacy Notice does not address our privacy practices relating to Smart Circle job applicants, employees, personnel, independent corporate distributors, and the sales representatives engaged by them. This Privacy Notice does not apply to content or websites operated by other companies that are linked to or from the Sites or to any content, platforms, services, products, or other functionality offered through services of third parties.

Smart Circle is the controller of personal information we hold about you in connection with your use of the Services. This means that we determine and are responsible for how your personal information is used. When our clients use our Services to submit, manage, or otherwise use content relating to our client’s customer’s data (“Customer Data”), we have contractually committed ourselves to only process such information on behalf of and under the instruction of the respective client, who is the “data controller”. This Privacy Notice does not apply to such Customer Data processing, and we recommend that customers read the privacy notice of the respective client, retailer, or other venue provider.

We value the privacy and security of your information. As such, we take complying with data privacy and security laws seriously.

UPDATES TO THE PRIVACY NOTICE

We will update this Privacy Notice as we adopt new practices and procedures related to your personal information, the Services, or applicable law. Any changes to this Privacy Notice will be placed here and will supersede this version. If we make changes to this Privacy Notice, we will revise the last updated date. If we make material changes to this Privacy Notice, we will provide notice or obtain consent regarding such changes as may be required by applicable law.

THE PERSONAL INFORMATION WE COLLECT ABOUT YOU

The personal information we collect depends on the Services and the choices you make. The personal information we collect costs of:

• Information You Provide to Us. Information you submit to us, such as information submitted to us in any request or provided to us when you communicate with us, use the Sites, or otherwise in connection with the Services. For example:
  • Contact information. We collect name, business name, username, email, address, and phone number.
  • Feedback or response information. If you provide feedback through the Services, or if you respond to a survey or other communication from Smart Circle or its agents, we may collect your response information, including the content of your feedback or response message.
  • Content and files. If you send us emails or other communications such as requests for customer support, fill out a form, or participate in a promotion, we may collect and retain those communications.
  • In some instances, this may include a recording of the Services, with your consent.
• Personal Data We Collect From Other Sources. We may collect personal data about you from other sources. For example, we may collect a business creditworthiness report. We may also collect aggregated data that identifies trends and facilitates ongoing analysis of the Services we perform. 
• Information Generated from The Use of the Services.
  • Device Information. Some portions of our Sites may use cookies, web beacons, pixel, or similar technology (collectively, “cookies”) to identify users who have previously visited so the user is recognized upon return. Smart Circle uses cookies to understand usage and to improve the content and offerings. We may use cookies to control the display of advertisements, track usage patterns on the Sites, deliver editorial content, and personalize information. Our cookies may contain personal information, and such cookies may be shared with others to the same extent indicated above. Smart Circle may also use cookies to collect and aggregate information about the Services. Some of our advertisers and third party applications may serve you cookies as well.
  • Log Data and Aggregate Information. When you visit our Sites, we may automatically collect technical and statistical information that your browser sends about your visit, including: internet service provider, your device’s Internet Protocol (IP) address, unique device identifiers (such as MAC address), device type, browser type, browser version, the time and date of your visit, the pages on our websites you visit, the time spent on those pages, and other statistics (“Log Data”). We may use Log Data in aggregate form to analyze trends, administer the Sites, track users’ movement, and gather broad demographic information for aggregate use. Such information will be in aggregate form only and it will not contain or link to personal information that can identify any individual person.
  • Deidentified Information. We may aggregate or deidentify personal information and use or disclose it at our discretion to support our business. Where we maintain deidentified information, we commit to maintaining and using such information in deidentified form and will not attempt to reidentify such information except as necessary to evaluate the effectiveness of our deidentification policies and procedures.

OUR USE OF PERSONAL INFORMATION

We use the personal information we collect for purposes described in this Privacy Notice or otherwise disclosed to you. For example, we use personal information for the following purposes:

• To provide Services to our clients. To communicate with you about the Services you use.
• To further the Services, for customer support and administrative messages, or to verify, process, or respond to a request submitted to us.
• To advertise and market the Services to you as a prospective or current client.
• To determine creditworthiness, reputation, and stability of potential entity clients, which we use to guide our financial and other decisions.
• For legal, security, and safety reasons, such as identity verification, protecting our rights and the rights of our clients, protecting the security of our systems, networks and facilities, detecting fraud, or addressing legal and regulatory compliance obligations.
• For any other purpose described to you at the time information is collected.

We may combine information we collect from different sources. Additionally, we may aggregate or deidentify personal information and use or disclose it at our discretion to support our business and in furtherance of the Services.

We may utilize products, features, or tools that utilize artificial intelligence, machine learning, or similar technologies for any of the above purposes.

WHETHER WE SHARE YOUR PERSONAL INFORMATION WITH OTHERS

We may share information provided to us with our vendors, clients, and business partners in connection with the Services, or with other third parties and service providers for the purpose of facilitating our business objectives.

• Vendors and Third Parties. We share personal information with vendors that provide services on our behalf or on behalf of our clients to operate and support our business objectives. For example, certain categories of de-identified transactional data are shared with our subcontractors to validate the Services performed, process payment to our subcontractors, and otherwise oversee campaign performance. This includes sharing with third parties providing transactional support, software to process or verify transactions, third party verification services, call center transaction processing, software development, and other forms of support services necessary to operate our business.    
• Affiliates and Related Companies. We disclose personal information to our parent, subsidiary, or affiliate entities, and partner entities.
• Corporate Transactions. We may transfer your personal information to another party as an asset that is part of a merger, acquisition, bankruptcy, restructuring, or other transactions in which another party assumes control of all or part of our business.
• For Legal Compliance. We may also share your personal information if necessary to: (1) comply with federal, state, or local laws; (2) comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; (3) cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local laws; (4) exercise or defend legal claims; (5) if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our business partners or others; or (6) to carry out our obligations and enforce our rights arising from any contracts.
• With Consent. To any other party with your consent.

HOW WE PROTECT YOUR PERSONAL INFORMATION

We have implemented and maintain reasonable security procedures and practices appropriate to the nature of the information designed to protect your personal information against accidental or unlawful destruction, loss, change or damage.

RETENTION OF PERSONAL INFORMATION

We retain personal information as required by our retention schedule, which varies by record classes and record types. Your personal information will be retained for the time required to fulfill the purposes for which it was collected and processed, including for the purpose of satisfying legal, professional, contractual, regulatory, accounting, or reporting obligations.

CHILDREN

Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children or minors under the age of 18. If an individual is under the age of 18, they should not use our Services or otherwise provide us with any personal information either directly or by other means. If a child under the age of 13 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 18, we will promptly delete that personal information.

EMAIL COMMUNICATIONS

You can opt out of receiving marketing emails from Smart Circle by notifying us at [email protected]. You can also opt out of receiving marketing emails by clicking the “unsubscribe” link on marketing communication. We may also email you in the case of emergency or other limited (non-marketing) instances as permitted by applicable law.

CALL, VOICEMAILS, AND TEXTING COMMUNICATIONS

No mobile opt-in data will be shared with third-parties/affiliates for their own marketing or promotional purposes. We may disclose mobile opt-in data to our service providers who process information solely as necessary to perform services on our behalf. You can opt-out of receiving marketing calls, voicemails, or texts (SMS) from Smart Circle by notifying us at [email protected] or replying to the SMS (text messages) with your desire to opt-out such as with “STOP” or “OPT OUT”. We may also call or text you in the case of emergency or other limited (non-marketing) instances as permitted by applicable law.

LINKS TO THIRD PARTY WEBSITES AND SHARING FEATURES

Some portions of our Sites or Services may contain links to and from third party websites, social networks, plug-ins, embedded content, or integrated tools enabling third party features (collectively, “Third Party Integrations”). Third Party Integrations are not operated, controlled, or maintained by Smart Circle. Any links to Third Party Integrations are provided solely for your convenience. Your interactions with any Third Party Integrations may enable the third party operating those Third Party Integrations to collect, use, or share data about you. Such Third Party Integrations does not constitute an endorsement by Smart Circle of such Third Party Integrations, their content displayed therein, and/or the persons or entities associated therewith. Your use of and interactions with any Third Party Integrations are subject to the respective terms of use and privacy policies of the third parties that provide these Third Party Integrations.  We encourage you to read their respective terms of use and privacy policies.

STATE SPECIFIC DISCLOSURES

ADDITIONAL INFORMATION FOR CALIFORNIA, NEBRASKA, AND TEXAS RESIDENTS

If you are a California, Nebraska, or Texas resident, you have the right under applicable state law to receive notice of the categories of personal information we collect, the purposes for which those categories of personal information are used or shared, how we determine the length of time for which the personal information is maintained, and your rights with regard to your personal information. Those details are outlined in this section.

COLLECTION AND USE OF PERSONAL INFORMATION

The following chart provides information about what we collect, how we use it, and additional retention considerations that arise when we apply these criteria to such information.

DISCLOSURE OF PERSONAL INFORMATION

We may disclose all of the categories of information we collect with third parties for a business purpose, as described in the Whether We Share Your Personal Information With Others section above. The categories of third parties to whom we sell or disclose your personal information for a business purpose include:

• Service providers and advisors that perform services for us, on our behalf, which may include providing marketing and advertising services, providing mailing or email services, tax and accounting services, data enhancement services, fraud prevention, web hosting, or similar services;
• Select marketing and strategic partners who use this information to market to you, to perform analytics and conduct research, or for other purposes;
• Ad networks and advertising partners, including social networks, to deliver advertising and personalized content to you on other sites and services you may use, and across other devices you may use, as well as provide advertising-related services such as reporting, attribution, analytics, and market research;
• Analytics providers to better understand the demographics of our users and visitors, and to personalize, enhance and improve our Service;
• We may also disclose personal information to other third parties at your direction or upon your request, or to comply with legal process or contractual obligations, as described in this Privacy Notice.

SALES AND SHARING OF PERSONAL INFORMATION

We may “sell” or “share” your personal information to third parties. A business “sells” personal information when it discloses personal information to a company for monetary or other benefit. A business “shares” personal information when it discloses personal information to a third party in order to engage in cross-context targeted advertising. A company may be considered a third party either because the purpose for its sharing of personal information is not for a business purpose under applicable law, or because its contract does not restrict it from using personal information for purposes outside of the provision of the services to us.

We sell or share your information as follows:

• Internet or Electronic Network Activity Information: to advertising, marketing, and analytics providers and to suppliers for marketing purposes.

RIGHT TO KNOW ABOUT PERSONAL INFORMATION COLLECTED, USED, AND RETAINED

California residents have the right to receive notice of the categories of personal information we collect, the sources from which we receive personal information, purposes for which we use personal information, and the criteria we use to determine the length of time we retain personal information. We utilize the following criteria to determine the length of time that we retain personal information:

• The business purposes for which the information is used, and the length of time the information is required to achieve those purposes.
• Whether we are required to retain the information or the information is otherwise necessary to: comply with legal obligations, comply with contractual commitments, defend against potential legal claims, detect or prevent potential illegal activity or fraud, or secure our systems and online environment.
• The privacy impact of ongoing retention.
• The manner the information is maintained and flows through our systems.

Individual pieces of personal information such as those listed above may exist in different systems and be used for different business or legal purposes, with different maximum retention periods applicable to each use of the information. Individual pieces of personal information may also be stored in combination with other information, and the maximum retention period may be determined by the purpose for which that information set is used.

UNIVERSAL OPT-OUT MECHANISM

Where available, you may choose to enable an online tool that automatically communicates your universal opt-out preferences, such as Global Privacy Control (“GPC”). You may need to use a specific browser or an extension that supports these tools and universal signals. When such signal is detected, we will process as a request to opt out of tracking personal information and as a request to opt out of “sale” or “sharing” your personal information as explained in “Your Privacy Choices” section below

YOUR PRIVACY CHOICES

California, Nebraska, and Texas residents have the right to request:

• To know the general categories of personal information we process;
• Access to your personal information we process, in a structured, commonly used, machine readable format;
• Deletion of certain personal information we have collected from you;
• Correction of inaccurate personal information;
• Opt out of selling or sharing your personal information with third parties;
• Withdraw consent in instances where the processing of data required your consent; and
• Appeal in the event we decline to take action on a request exercising one of your rights

You also have the right not to receive discriminatory treatment for the exercise of your privacy rights.

HOW TO EXERCISE YOUR PRIVACY RIGHTS

You may submit a request concerning your personal information by calling us at 800-556-5514 or filling out the web form here: https://smartcircle.com/data-rights-request/ .

Once you contact us through one of these channels, we will need to confirm your identity to process your request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information that relates to you. We will only use personal information provided in connection with the verification process to verify your identity or the authority of your authorized agent. For requests to correct inaccurate information, we may ask you to provide documentation that demonstrates why or how the existing information is inaccurate.

RIGHT TO OPT-OUT OF THE SALE AND SHARING OF PERSONAL INFORMATION

For Cookie-Based Sales & Targeted Advertising Opt-Outs: To exercise your right to opt-out as it relates to the use of cookies and other tracking technologies for analytics and targeted ads, please click on the “Cookies Settings” link on the footer of our Sites.

RIGHT TO LIMIT PROCESSING OF SENSITIVE PERSONAL INFORMATION

California, Nebraska, and Texas residents, and their authorized agents, have the right to request that a business limit its processing of sensitive personal information under certain circumstances. However, Smart Circle processes sensitive personal information only as permitted by applicable law and only to:

• Provide Services as requested by you or as reasonably expected.
• To prevent, detect, and investigate security incidents or otherwise protect our business or systems from fraud or other illegal activities. To pursue legal action against parties involved in such activities.
• For short term, transient use to personalize your experience with our Services.

Accordingly, Smart Circle does not offer an option to limit further processing of sensitive personal information.

AUTHORIZED AGENT

You may use an authorized agent to submit requests on your behalf to exercise the rights above. Before accepting a request form an authorized agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us to confirm that you provided the authorized agent permission to submit the request.

CALIFORNIA’S SHINE THE LIGHT DISCLOSURE

The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. To submit a data rights request, please fill out the web form here: https://smartcircle.com/data-rights-request/.

CANADA SPECIFIC NOTICE

NOTICE TO INDIVIDUALS IN CANADA

This Notice applies to individuals in Canada about whom we may have collected personal data. We provide this Notice in addition to the disclosures throughout the rest of this Privacy Policy to comply with applicable laws, including the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and/or provincial privacy laws.

For the purposes of this Notice, “personal data” means information about an identifiable individual. Personal data does not include any business contact information that is solely used to communicate with you in relation to your employment, business or profession, such as your name, position name or title, work address, work telephone number, or work email address. Personal data also does not include information that has been de-identified, anonymized, or aggregated in such a way that there is no serious possibility it can be used to identify an individual, whether on its own or in combination with other available information.

LEGAL BASES FOR PROCESSING

We rely on one or more legal bases to process your personal data under applicable law. We may process personal data (i) as necessary to perform our contractual obligations to you, including, but not limited to, those obligations in our Terms of Use at https://smartcircle.com/terms/; (ii) as necessary to pursue our legitimate business interests as further detailed below; (iii) as necessary for our compliance with our legal obligations such as a request or order from courts, law enforcement or other government authorities; and/or (iv) with your consent.

We may collect, process, and maintain personal data to pursue the legitimate business interests outlined below. To determine these legitimate interests, we balance our legitimate interests against the legitimate interests and rights of you and others and only process personal data in accordance with those interests where they are not overridden by your data-protection interests or fundamental rights and freedoms. Our legitimate interests generally include:

• Providing, improving, and developing our Services, including to deliver your requested services, send you messages and provide user support, customize the Services, develop new products and services, and perform internal analytics and research and development. This also includes making available personal data to our trusted service providers that provide services on our behalf.
• Protecting you and others and to create and maintain a trusted environment, such as to comply with our legal obligations, to ensure compliance our agreements with you and other third parties, to ensure safe, secure, and reliable Services, and to detect and prevent wrongdoing and crime, assure compliance with our policies, and protect and defend our rights, interests, and property. In connection with the activities above, we may conduct internal research and profiling based on your interactions on various Services, content you submit to the Services, and information obtained from third parties.
• Providing, personalizing, measuring, and improving our marketing, including to send you promotional messages and other information that may be of interest to you with your consent. We may also use personal data to understand our user base and the effectiveness of our marketing. This processing is done pursuant to our legitimate interest in undertaking marketing activities to offer products or services that may be of interest to you.

CANADIAN PRIVACY RIGHTS

Individuals in Canada may have the following privacy rights, subject to certain exceptions:

• Right to Access. You have the right to request confirmation of whether we process personal data relating to you, and if so, to request a copy of that personal data.
• Right to Correct. You have the right to request to have your personal data corrected or updated if that information is inaccurate, outdated, or incomplete.
• Right to Withdraw Consent. If you have already consented to the collection, use, and/or disclosure of your personal data, you may subsequently withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice.

To exercise your privacy rights described above, please call us at 800-556-5514. Any request you submit to us is subject to an identification and residency verification process as permitted under applicable law. Additionally, all requests are subject to certain exceptions under applicable law, which may vary.

If you have any questions or concerns about our privacy practices, please contact us at 800-556-5514 or by emailing l[email protected]. You may also contact the Office of the Privacy Commissioner at 800-282-1376 if you are unsatisfied with our response to your privacy concern.

CONTACTING US

If you have any questions regarding this Privacy Notice, you may contact us by calling 800-556-5514 or by emailing [email protected].
                                                                                 (Privacy Notice last updated 04/15/2026)