Privacy policy

Last updated: 11 October 2026

This privacy policy explains how the Circle app (the "app") processes its users' personal data. The data controller is a natural person doing business under the Digital Ecosystem brand, who operates the app and the website digital-ecosystem.cz; contact: info@digital-ecosystem.cz. The policy also applies to the web version of the app at digital-ecosystem.cz/app/, which stores your sign-in in the browser.

1. What data we collect

Registration and profile data

• E-mail address — used to create the account and sign in
• Username — the publicly visible name in the app
• Profile and cover photo, bio — optional, publicly visible, stored on our server in the Czech Republic
• Unique user ID (UID) — generated by our server

User-generated content

• TrustBits — posts (text, images, videos) stored on our server in the Czech Republic
• TrustShots (stories) — shots from both cameras, temporary content automatically deleted from the server after 24 hours
• Direct messages — private conversations between two users are encrypted between devices (end-to-end); the server only relays and stores encrypted data that we cannot read. The keys stay on the phone.
• Circles — the topic you choose, group membership and posts with the group hashtag (public)
• Comments and likes — interactions with other users' posts

Technical and operational data

• FCM token — an anonymous token for delivering push notifications
• Online status / last seen — stored on our server in the Czech Republic
• IP address and logs — processed automatically by the operation of our servers in the Czech Republic
• Bug and content reports — text, category, an optional screenshot and IP address; read by the administrator in the Circle Admin tool; please mask other people's personal data on the screenshot

2. How we use the data

• Operating and providing the social network's features
• Delivering push notifications (new likes, comments, messages)
• Content moderation — content is checked both automatically (Digital Eye, directly on the phone) and by hand; uploaded content is not sent to any external service for analysis
• Preventing abuse and keeping the platform secure

3. Legal basis for processing

• Performance of a contract (Art. 6(1)(b) GDPR) — running your account and providing the app's features, including Shop purchases and subscriptions; on the website also Founders' Club membership (order, payment, receipt, your number in the Founders' Hall, the voting code and sending the development diary to members by e-mail)
• Legitimate interest (Art. 6(1)(f) GDPR) — platform security, server logs, abuse prevention and handling reports
• Consent (Art. 6(1)(a) GDPR) — optional profile data (photo, bio), beta access requests and publishing your nickname in the Founders' Hall on the website; you can withdraw consent at any time, and we hide the nickname within 7 days of withdrawal

4. Sharing data with third parties

We do not sell your data to third parties. Content, profiles and messages are stored on our servers in the Czech Republic. Beyond them, data reaches only the following services, and only to the extent stated:

• Our servers (Czech Republic) — sign-in (e-mail and password, stored only as a hash), profiles, posts, messages, comments, notifications and uploaded files. The data stays in the EU. The app fetches new notifications from our servers itself; no third-party service delivers them.
• Google Play Billing — Shop purchases. Google processes the payment under its own terms; we receive only the order identifier and the purchased product, never payment details.
• Stripe Payments Europe Ltd. (Ireland) — only when paying by card for Founders' Club membership on the website. You enter your card on Stripe's payment page and Stripe processes it under its own terms; we see the e-mail address, amount, nickname, publication consent and payment identifier, never the card number. A bank transfer involves no third party: we see the account holder's name on our bank statement and any refund goes back to the same account.

Uploaded content is not sent to any external service for analysis.

5. Transfers outside the EU

Data reaches only two recipients outside the EU. Google LLC (USA) for the Google Play Billing service (in-app purchases). Stripe Payments Europe Ltd. may transfer card payment data for Founders' Club membership within the Stripe group to the USA (Stripe, Inc.). Both transfers rely on the European Commission's adequacy decision (EU–US Data Privacy Framework) and on standard contractual clauses. Content, profiles and messages remain on our server in the Czech Republic.

6. Retention period

• Account data — kept for as long as the account exists, i.e. until it is deleted
• TrustShots (stories) — automatically deleted after 24 hours
• Direct messages — kept (encrypted) until the user deletes them
• Server logs with IP address — 90 days
• Bug and content reports — until resolved, at most 12 months
• Beta access requests — until processed, at most 12 months
• Founders' Club orders and receipts — for the period required by tax and accounting law
• Nickname in the Founders' Hall — until consent is withdrawn (hidden within 7 days); the founder number for as long as the website runs
• Club voting code — we store only its hash and last four characters, until the code is invalidated (withdrawal, refund, issue of a new code)
• After account deletion — all data is permanently removed within 30 days

7. Automated evaluation

Trust Score and Circles evaluate account activity automatically (for example reactions to posts, reports, blocks or the topics you post about). This evaluation has no legal effects; it only affects the visibility of posts and group suggestions. We do not publish the exact Trust Score formula so that it cannot be gamed.

8. Your rights (GDPR)

You have the following rights:

• Right of access — you can request a copy of your data
• Right to rectification — you can correct inaccurate data directly in the app
• Right to erasure — deletion of the account and all data (see Account deletion)
• Right to restriction of processing — while we verify the accuracy of the data or assess your objection
• Right to data portability — you can request an export of your data
• Right to object — to processing based on legitimate interest
• Right to withdraw consent — for data processed on the basis of consent, at any time and without affecting earlier processing

To exercise any of these rights, contact us at: gdpr@digital-ecosystem.cz

Right to lodge a complaint. If you believe we process your data in breach of the law, you can lodge a complaint with the supervisory authority: Úřad pro ochranu osobních údajů (Office for Personal Data Protection), Pplk. Sochora 27, 170 00 Praha 7, Czech Republic, www.uoou.cz.

9. Security

We keep data secure by means of:

• Access to data on the server is restricted to the signed-in user; other people's messages and notifications cannot be loaded
• Passwords are stored only as hashes, never in readable form
• All communication is encrypted (TLS)
• Rate limits on sign-in and registration attempts as protection against password guessing
• Chat encryption keys stay on your device

10. Age limit

The Circle app is not intended for people under 13. We do not knowingly collect personal data from children. If we find that we have unintentionally collected data from a child, we delete it without delay.

11. The digital-ecosystem.cz website

A beta access request on the website contains a name, e-mail address and message; alongside it we process the IP address to limit the number of requests. The Founders' Club form processes your e-mail address, nickname, consents (to the Club terms, to publishing the nickname and the age confirmation) and IP address to limit the number of orders and poll votes. When any page loads, nothing is sent to a third party; you only move to Stripe's payment page by clicking the card payment button. The number of visits to Stripe is counted on our servers only, without cookies and without identifying the visitor. The website uses only a technical session cookie and localStorage for the chosen theme, neither of which requires consent. The Inter font is served from our servers (not from Google Fonts), so loading a page sends no data to Google or any other third party. We use no analytics and no advertising cookies. The web version of the app at /app/ stores your sign-in in the browser and otherwise follows the same policy as the mobile app.

12. Changes to this policy

We may update this policy from time to time. We will inform you of substantial changes through a notice in the app or by e-mail. The date of the last update is shown at the top of this document.

13. Contact

For questions or requests about privacy, contact us:

• Personal data (GDPR): gdpr@digital-ecosystem.cz
• Other questions: info@digital-ecosystem.cz
• Web: digital-ecosystem.cz