Privacy Policy

Privacy Policy

Last updated August 2, 2026

Circo ("Company", "we", "us", or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use the Circo desktop application (the "Application" or "Software") and any associated services (collectively, the "Services").

This policy has been designed to comply with the General Data Protection Regulation (GDPR), the California Consumer Privacy Act of 2018 (CCPA) as amended by the California Privacy Rights Act (CPRA), and the Developer Policies of major platforms (including Google and Microsoft).

1. Compliance Statement and Principles

We adhere to the core principles of data protection:

• Data Minimization: We collect only the personal information strictly necessary for core application functionality.
• Transparency: We provide clear explanations of what data is collected, why it is processed, and where it is sent.
• User Control: We respect your rights to access, restrict, and delete your data.
• Security by Design: We use operating system-level encryption for local storage and transport-level security for all API calls.

2. Information We Collect and Process

When you interact with the Software, we collect personal data and technical information across four distinct categories:

2.1 Hardware Fingerprinting (License Validation)

To enforce query limits in Guest and Trial tiers, manage active Pro subscriptions, and prevent license sharing or abuse, the Software generates a pseudonymous hardware fingerprint.

• Mechanism: The Software queries the Windows Management Instrumentation (WMI) interface using the Win32_ComputerSystemProduct class to retrieve system identifiers, specifically the hardware UUID (Universally Unique Identifier) and serial number.
• Data Collected: Hardware UUID, Motherboard Serial Number, and OS version.
• Purpose: Verification of subscription status, mapping active devices to user accounts, and trial limit enforcement.
• Storage & Transfer: This fingerprint is hashed locally, sent over an encrypted HTTPS connection, and stored securely on our Firestore backend. It is never shared with third-party advertisers.

2.2 Local OS Keychain Storage (safeStorage)

To manage active sessions securely without exposing access tokens:

• Mechanism: The Software utilizes Electron's native safeStorage API.
• Data Stored: Your account credentials, license keys, and API authentication tokens.
• Security: This data is encrypted using OS-level credential management systems (specifically DPAPI, the Data Protection API, on Windows).
• Access: This data remains stored exclusively on your local device. The Company cannot access your local OS keychain, and this information is never transmitted to our servers or any third parties.

2.3 Telemetry and Application Usage Data

To monitor stability, patch crashes, and optimize performance:

• Data Collected: Application version, feature interaction counts (e.g., number of visual searches executed), run state (active/inactive), memory footprint telemetry, error stacks, and exception logs.
• Sub-processor: Telemetry data is collected and processed using Firebase and stored in Google Firestore.
• Opt-out: Users can opt-out of optional telemetry collection in the Application's settings panel.

2.4 Temporary Screen Capture and Visual Search Processing

The core function of Circo is "visual search" (allowing you to crop a section of your screen to search the web).

• Local Image Cropping: When you trigger a visual search, the Software takes a screen capture. This capture and any subsequent cropping occur entirely locally and in-memory (or temporarily in the operating system's standard temporary directory).
• Direct API Transmission: The cropped image file is immediately transmitted via secure HTTPS directly to Google Lens and/or third-party visual search engine APIs.
• NO Persistent Local or Server Storage:
  • Circo does NOT persistently store screen captures, cropped images, or search history on your local disk.
  • Circo does NOT upload, store, or process screen captures on the Company's servers.
  • Circo does NOT record your screen in the background or stream screen contents.
  • Circo does NOT persistently store, analyze, train AI models on, or transmit your screen captures to any servers other than the selected search engines required to complete your search request.
• Third-Party Processing: Images sent to Google Lens are processed in accordance with Google's Privacy Policy. Google uses these images to return search results, and their usage is subject to Google's standard developer terms.

3. No Sale or Sharing of Personal Data

4. Legal Bases for Processing (GDPR & UK GDPR)

Under the GDPR, we process your personal data based on the following lawful bases:

1. Contractual Necessity (Art. 6(1)(b) GDPR): Processing is required to fulfill our contract with you, specifically to validate licenses, verify active Pro subscriptions, and execute visual searches.
2. Legitimate Interests (Art. 6(1)(f) GDPR): Processing is necessary for our legitimate business interests, including preventing fraud and trial limit abuse (via hardware fingerprinting), troubleshooting system errors (via Firebase telemetry), and securing the Software.
3. Consent (Art. 6(1)(a) GDPR): For optional analytical telemetry where you have explicitly opted-in via the Application settings.

5. California Privacy Rights (CCPA/CPRA)

If you are a California resident, the CCPA/CPRA provides you with specific rights regarding your personal information:

5.1 Categories of Information Collected

In the preceding 12 months, we have collected the following categories of information:

• Identifiers: Hardware UUID, serial number, email address (if registered).
• Internet or Other Electronic Network Activity: Firebase telemetry, interaction logs, error reports.
• Geolocation Data: Coarse location (country/region level derived from IP address for payment processing).

5.2 Your Rights under CCPA/CPRA

• Right to Know/Access: You have the right to request disclosure of the specific pieces of personal information we have collected about you.
• Right to Delete: You have the right to request the deletion of your personal information collected by us, subject to exceptions (such as complying with legal obligations or billing reconciliation).
• Right to Correct: You have the right to request correction of inaccurate personal data.
• Right to Opt-Out of Sale or Sharing: Because we do not sell or share your data, no opt-out is necessary.
• Non-Discrimination: We will not discriminate against you for exercising your CCPA/CPRA rights.

6. User Data Rights (GDPR, CCPA & Other Laws)

Regardless of your geographic location, we provide comprehensive rights controls to all users:

6.1 Right of Access and Portability

You may request a copy of the telemetry and registration data we have associated with your account and hardware fingerprint by contacting us at contact@trycirco.com.

6.2 Right to Erasure ("Right to be Forgotten")

You may request the permanent deletion of your account, email registration, telemetry logs, and hardware fingerprint database records.

Note: Upon erasure, you will immediately lose access to any active Trial or Pro subscriptions associated with those hardware fingerprints, and the Software will revert to the Guest Tier.

6.3 Verification Process

To protect your privacy, data access or deletion requests will require verification. We will verify your request by sending a confirmation code to your registered email address or verifying ownership of the hardware fingerprint.

7. Third-Party Sub-processors

We share data with the following sub-processors to maintain and run the Services:

Sub-processor	Purpose	Location	Privacy Link
Google Cloud / Firebase	Telemetry, error logging, licensing backend database (Firestore)	United States	Google Privacy Policy
Google Lens API	Visual search query processing	Global	Google APIs Terms
Stripe / Paddle	Subscription payment processing & fraud prevention	Global	Stripe Privacy Policy

8. Data Retention Policy

We retain personal information only as long as necessary to fulfill the purposes for which it was collected:

• Hardware Fingerprints: Retained as long as your account is active or for up to one (1) year after your subscription expires to prevent billing fraud and trial abuse.
• Telemetry Logs: Firebase error logs and application telemetry are automatically deleted or aggregated after ninety (90) days.
• Visual Search Images: Deleted instantly from local memory/temp folders upon API completion. Images are never uploaded or stored on Circo's servers.

9. Data Security

We implement robust administrative, technical, and physical security measures:

• Transit Security: All network communications between the Software and our servers or third-party APIs use industry-standard HTTPS with Transport Layer Security (TLS 1.2 or TLS 1.3).
• Storage Security: All backend databases are encrypted at rest using Advanced Encryption Standard (AES-256).
• Local Security: Local tokens are stored using Windows DPAPI encryption via Electron safeStorage.

10. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. When changes are made, we will update the "Last Updated" date at the top of this page. If the changes are material, we will provide a notification within the Application interface or send an email to registered users.

11. Contact and Complaints

If you have questions, comments, or complaints about this Privacy Policy or our data handling practices, please contact our Data Protection Officer (DPO):

Circo Privacy Team
Email: contact@trycirco.com
Web Form: https://trycirco.com/privacy-request

If you reside in the EEA or UK and believe we have processed your personal data unlawfully, you have the right to lodge a complaint with your local data protection supervisory authority.