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April 23, 2026

Cirqley (“Cirqley,” “we,” “us,” or “our”) respects your privacy. This Privacy Policy explains how we collect, use, disclose, and protect information when you visit cirqley.com (the “Website”), communicate with us, or engage our digital marketing services (the “Services”). It also describes the choices and rights you have regarding your information.
This Privacy Policy applies to information we collect as a business (a “controller” or “business”) about visitors to our Website, prospects, and our clients and their authorized representatives. It does not apply to information we process on behalf of our clients in our role as a service provider, which is governed separately in Section 10 below.
By using the Website or engaging our Services, you acknowledge that you have read and understood this Privacy Policy.

Information We Collect

We collect the following categories of information:

Information You Provide to Us

  • Contact and identifying information: name, email address, phone number, mailing address, company or law firm name, job title, and practice area.
  • Account and engagement information: billing contact details, authorized users, point-of-contact preferences, and information you provide during onboarding or project scoping.
  • Content and materials: any content you submit to us through forms, email, chat, or uploaded files, including documents, images, and written instructions.
  • Payment information: we do not store full payment card numbers ourselves. Payment details are collected and processed by our payment processor, Stripe, Inc., under Stripe’s own privacy policy. We retain transaction records, invoice metadata, and the last four digits of the card used.
  • Communications: records of your communications with us, including emails, SMS/text messages, and support requests.

Information We Collect Automatically

When you visit the Website, we and our third-party providers automatically collect:
  • Device and technical information: IP address, browser type and version, operating system, device identifiers, screen resolution, and language preferences.
  • Usage information: pages viewed, time spent on pages, links clicked, referring URL, exit pages, and date/time stamps.
  • Location information: approximate geographic location derived from IP address (city/region level; not precise GPS).
  • Cookie and tracking data: described in Section 4 below.

Information From Third Parties

We may receive information about you from:
  • Advertising platforms (Google, Meta, LinkedIn) regarding ad engagement and conversions attributed to you;
  • Analytics providers (Google Analytics and similar) regarding your interactions with the Website;
  • Publicly available sources such as business directories and professional networking platforms, used for prospecting and outreach; and
  • Referrals from existing clients or partners.

Sensitive Personal Information

We do not intentionally collect sensitive personal information (as defined under California law), such as government ID numbers, precise geolocation, racial or ethnic origin, health information, or financial account credentials. If you provide this information voluntarily, we will handle it in accordance with this Privacy Policy.

How We Use Your Information

We use the information we collect for the following business purposes:
  • Responding to your inquiries, proposals, and support requests;
  • Providing, performing, and improving the Services under our Terms of Service and any executed SOW;
  • Billing, invoicing, and collecting payments;
  • Sending transactional communications (invoices, receipts, service updates, scheduling);
  • Sending marketing communications about our Services, where permitted and subject to your ability to opt out;
  • Operating, securing, monitoring, and improving the Website;
  • Conducting analytics and measuring marketing effectiveness;
  • Personalizing your experience on the Website;
  • Detecting, preventing, and responding to fraud, abuse, security incidents, and unlawful activity;
  • Complying with legal obligations, responding to lawful requests, enforcing our Terms, and protecting our rights and the rights of others;
  • Corporate transactions (diligence, mergers, acquisitions, or asset sales, subject to confidentiality protections).
We do not sell your personal information in exchange for money. However, because we use advertising cookies and pixels (see Section 4), some uses of your information may qualify as a “sale” or “sharing” under California law for cross-context behavioral advertising purposes. See Section 8 for your opt-out rights.

How We Share Information

We disclose your information only in the following circumstances:
  • Service providers. We share information with vendors and contractors who perform services on our behalf under written contracts that limit their use of the information. These include:
  • Stripe, Inc. (payment processing)
  • Google LLC (Google Analytics, Google Ads, Google Workspace)
  • Meta Platforms, Inc. (Meta Pixel and advertising)
  • LinkedIn (advertising and insights)
  • Website hosting, email delivery, CRM, helpdesk, calendaring, and communications platforms
  • Chat/messaging platform(s) used on the Website
  • Advertising and analytics partners. As described in Section 4, third-party cookies and pixels on the Website allow advertising partners to collect information about your visit and serve ads to you on other sites. Under California law, this constitutes “sharing” of personal information.
  • Professional advisors. Our accountants, auditors, attorneys, and insurers, under obligations of confidentiality.
  • Corporate transactions. In connection with a merger, acquisition, financing, reorganization, or sale of assets, subject to reasonable confidentiality protections.
  • Legal and safety. When we believe disclosure is required by law, court order, subpoena, or governmental request; to enforce our Terms; to protect the rights, property, or safety of Cirqley, our clients, our users, or the public; or to investigate fraud or security incidents.
  • With your consent or at your direction.
We do not sell personal information for monetary consideration, and we do not share mobile phone numbers or SMS opt-in data with third parties or affiliates for their marketing or promotional purposes. See Section 6.

Cookies, Pixels, and Tracking Technologies

We and our third-party providers use cookies, web beacons, pixels, tags, local storage, and similar technologies (collectively, “Cookies”) to operate and improve the Website, measure performance, and deliver advertising.

Categories of Cookies We Use

  • Strictly necessary Cookies — required for the Website to function (e.g., security, session management). These cannot be disabled.
  • Analytics Cookies — help us understand how visitors use the Website. Primarily Google Analytics. These Cookies collect information such as pages visited, time on site, and referring URLs in aggregated and pseudonymized form.
  • Advertising Cookies — used to deliver relevant ads on other websites and measure ad performance. These include the Meta Pixel, LinkedIn Insight Tag, Google Ads conversion and remarketing tags, and similar technologies from our advertising partners.
  • Functional Cookies — remember your preferences and support features like chat widgets.

Categories of Cookies We Use

Most web browsers let you control Cookies through browser settings. You can also:
  • Opt out of Google Analytics via the Google Analytics Opt-Out Browser Add-On (tools.google.com/dlpage/gaoptout);
  • Adjust ad personalization in your Google Account at adssettings.google.com;
  • Adjust your Meta ad preferences at facebook.com/ads/preferences;
  • Opt out of interest-based advertising at optout.aboutads.info (DAA) or optout.networkadvertising.org (NAI).
Disabling Cookies may impair some features of the Website.

Do Not Track and Global Privacy Control

Our Website does not currently respond to browser “Do Not Track” signals because there is no common industry standard for interpreting them. We do honor the Global Privacy Control (GPC) browser signal for users located in states whose laws require us to recognize it, as a valid request to opt out of the sale or sharing of personal information for cross-context behavioral advertising.

Data Retention

We retain personal information only as long as reasonably necessary for the purposes described in this Privacy Policy, or as required by law. Typical retention periods are:
  • Client account and engagement records: duration of the engagement plus seven (7) years for tax, accounting, and legal purposes.
  • Billing and transaction records: seven (7) years, consistent with tax and accounting requirements.
  • Marketing prospect data: up to two (2) years from last meaningful contact, unless you opt out sooner.
  • Website analytics data: up to twenty-six (26) months (Google Analytics default).
  • SMS opt-in records: duration of consent plus four (4) years after opt-out, to demonstrate compliance with TCPA.
  • Communications (email, chat, SMS): up to seven (7) years for client communications; up to two (2) years for other inquiries.
We may retain information longer where required by law, necessary to resolve disputes, or appropriate to enforce our agreements.

SMS / Text Message Privacy

Cirqley may send SMS/text messages to clients and authorized client contacts as part of our Cirqley Client Care program. This section supplements the SMS terms in our Terms of Service.
  • Express consent required. We send SMS messages only to individuals who have provided their mobile number and consented to receive text messages from Cirqley. Consent is not a condition of purchasing any Service.
  • Use of mobile number. Your mobile phone number and SMS opt-in data are used solely to deliver messages you have consented to receive and to comply with applicable law.
  • No sharing. No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All other categories of information disclosure described in this Privacy Policy exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
  • Opt-out. You may opt out at any time by replying STOP to any Cirqley text message. Reply HELP for assistance. You may also email info@cirqley.com.
  • Cost. Message and data rates may apply.
  • Supported carriers. Messages are supported on major U.S. wireless carriers. Carriers are not liable for delayed or undelivered messages.

How We Protect Your Information

We use administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction. Measures include TLS/SSL encryption of data in transit, access controls, least-privilege principles for personnel, and vendor agreements that require reasonable security.
No method of electronic transmission or storage is 100% secure. While we use commercially reasonable measures, we cannot guarantee absolute security. If a security incident affects your information, we will notify you as required by applicable law.
You are responsible for maintaining the security of any credentials you use to access our systems and for promptly notifying us of any suspected unauthorized access.

Your Rights and Choices

Data Retention

Regardless of your state, you may:
  • Opt out of marketing emails by clicking the unsubscribe link at the bottom of any marketing email, or by emailing info@cirqley.com.
  • Opt out of SMS by replying STOP to any Cirqley text message.
  • Request access, correction, or deletion of your personal information by contacting us as described in Section 11. We will respond consistent with applicable law.

California Residents (CCPA/CPRA)

If you are a California resident, you have the following rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act:
  • Right to know. You may request that we disclose the categories and specific pieces of personal information we have collected about you, the categories of sources, the business or commercial purposes for collecting or sharing, and the categories of third parties with whom we share personal information. This right covers the preceding 12 months (and beyond, for requests submitted on or after January 1, 2023, where technically feasible).
  • Right to delete personal information we have collected about you, subject to exceptions (e.g., completing transactions, detecting fraud, complying with law).
  • Right to correct inaccurate personal information.
  • Right to opt out of sale or sharing. Cirqley does not sell personal information for monetary consideration. However, we use third-party advertising cookies and pixels (including Meta Pixel and Google Ads tags) that may constitute “sharing” of personal information for cross-context behavioral advertising. You may opt out by:
  • Emailing info@cirqley.com with the subject line “Do Not Sell or Share”;
  • Submitting a Global Privacy Control (GPC) signal through your browser, which we will honor as a valid opt-out request; or
  • Using the cookie preferences controls on the Website, if available.
  • Right to limit use of sensitive personal information. We do not use sensitive personal information for purposes requiring this opt-out. If that changes, we will update this Privacy Policy.
  • Right to non-discrimination. We will not discriminate against you for exercising any of these rights.
  • How to exercise California rights. Submit a request by emailing info@cirqley.com or calling (206) 866-1719. We will verify your identity before responding (typically by confirming information you have previously provided to us). You may use an authorized agent by providing signed written authorization. We will respond within 45 days, with a possible 45-day extension on notice.
  • Do Not Sell or Share My Personal Information: [Insert link to opt-out page or cookie preferences].

Residents of Other U.S. States

Residents of Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), Texas (TDPSA), Oregon, Montana, and other states with comprehensive privacy laws have similar rights, including rights to access, correct, delete, obtain a portable copy of their personal information, and opt out of targeted advertising and the sale of personal information. To exercise these rights, contact us at info@cirqley.com. You have the right to appeal a denial of your request by replying to our response with “Appeal.”

Do Not Track

See Section 4.3.

Children’s Privacy

The Website and Services are intended for business and professional users and are not directed to children under 16. We do not knowingly collect personal information from children under 16. If you believe a child has provided personal information to us, please contact us at info@cirqley.com and we will promptly delete it.

Information Processed on Behalf of Clients

When Cirqley performs Services for a client — for example, managing a client’s website, CRM, lead forms, advertising campaigns, or email lists — we may collect or access personal information about the client’s own end users (such as names and email addresses submitted through a client’s website contact form).

With respect to that information, Cirqley acts as a service provider, processor, or agent on behalf of our client, not as an independent controller or business. The client is the party responsible to those end users under applicable law, and the client’s own privacy policy governs the collection and use of that information.

Cirqley:

  • Processes such information only as necessary to perform the Services under the client’s instructions and our agreement with the client;
  • Does not sell, share, retain, use, or disclose such information for any purpose other than performing the Services;
  • Does not combine such information with information from other sources except as permitted by applicable law;
  • Implements reasonable security measures to protect such information; and
  • Will assist the client, to the extent reasonably required, in responding to verified end-user requests regarding such information.
End users of our clients who wish to exercise privacy rights over their information should contact the client (the law firm or business whose website they submitted their information through), not Cirqley directly. Cirqley will forward any such requests we receive to the relevant client.

Third-Party Websites and Services

The Website may contain links to third-party websites, advertisements, or integrated third-party tools. We are not responsible for the privacy practices of those third parties. We encourage you to read their privacy policies before providing any information to them.

International Users

The Website and Services are intended for users in the United States. If you access the Website from outside the United States, you acknowledge that your information will be transferred to and processed in the United States, which may have different data protection laws than your jurisdiction.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The “Last Updated” date at the top reflects the most recent version. Material changes will be communicated by posting a notice on the Website or by email where appropriate. Your continued use of the Website or Services after the effective date of an updated Privacy Policy constitutes acceptance of the changes.

Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or your personal information, please contact:

Cirqley