Privacy
This policy explains what personal data Circle247 collects, why, and the rights you have over it. Circle247 is a family safety app: only Guardians pay, the people being cared for are always free, and everything we do is built around consent and care rather than tracking for its own sake.
Who we are
Circle247 Ltd (we, us) is the data controller for the personal data described here. We are registered in England and Wales, based in Preston, Lancashire, United Kingdom. Company registration number [to confirm]. Our ICO registration reference is [to confirm]. You can reach us any time at hello@circle247.co.uk.
The data we collect
- Account data: your name, email address, the circle you belong to, and your role (Guardian or Member). Guardians set up the circle and invite Members.
- Precise location: when you are a Member, the app shares your device location with your inner circle. Location is central to the service and is only collected with your permission, which you can withdraw in your device settings at any time.
- SOS events: when an SOS is raised we record the alert, a location pin, the time, and which Guardians acknowledged it. This is the safety record of what happened.
- Device data: a push notification token, device type and operating system, app version, and basic diagnostics needed to deliver alerts and keep the app working.
- Payment data: for Guardians who subscribe, billing is handled by our payment processor. We receive a record of the subscription but not your full card details.
How we use it and our lawful bases
| What we do | Lawful basis (UK GDPR) |
|---|---|
| Run your account and your circle | Performance of our contract with you |
| Share live location with your inner circle | Your consent (and, for a child Member, the consent of a person with parental responsibility) |
| Send SOS alerts and safety notifications | Our contract with you, and your vital interests where someone's life or safety is at risk |
| Keep the service secure and prevent misuse | Our legitimate interests in a safe, reliable service |
| Take subscription payments from Guardians | Performance of our contract with you |
| Meet legal, tax and regulatory duties | Compliance with a legal obligation |
We do not use your data for advertising, and we never sell it.
Children's data
Members are often children, so we designed Circle247 to meet the UK Children's Code. A Guardian with parental responsibility sets up a child's membership and provides consent. We collect the minimum needed to keep a child safe, we do not profile children or serve them adverts, and we keep settings private by default. There is a dedicated, plain-English notice for children on our Children's Privacy page.
Who we share it with
- Your circle: sharing location and SOS alerts within your chosen circle is the point of the service. You control who is in your circle.
- Service providers: hosting, payment processing, push notifications and map services, each acting on our instructions under contract.
- Emergency and legal: where necessary to protect someone's life, or where we are required to by law or a valid legal request.
We do not sell your data or share it with advertisers or data brokers.
Where your data is held
Your data is hosted on servers in the United Kingdom or European Economic Area. If any provider processes data outside the UK or EEA, we put appropriate safeguards in place, such as the UK International Data Transfer Agreement or an adequacy decision.
How long we keep it
| Data | Retention |
|---|---|
| Account data | While your account is active, then deleted within 30 days of closure |
| Live location | Held only to power live sharing; location history is not kept beyond 24 hours unless it forms part of an SOS event |
| SOS events | Kept for 12 months as a safety record, then deleted or anonymised |
| Device and diagnostic data | Up to 12 months |
| Payment records | As long as the law requires, typically 6 years for tax |
Retention periods and the data list above are the intended policy and should be confirmed against the live product before this page is relied upon.
Your rights
Under UK GDPR you have the right to access your data, correct it, delete it, restrict or object to how we use it, receive a copy in a portable format, and withdraw consent at any time. To exercise any of these, see Your Data Rights or email hello@circle247.co.uk.
Cookies
We use essential cookies only. See our Cookie Policy.
Making a complaint
We hope to resolve any concern directly, so please contact us first. You also have the right to complain to the Information Commissioner's Office (ICO), the UK regulator, at ico.org.uk/make-a-complaint or on 0303 123 1113.
Changes to this policy
If we change this policy we will update the date at the top and, for significant changes, tell you in the app or by email.