The entities comprising Dreamplug Technologies Private Limited (DTPL), its subsidiaries, and affiliated companies (collectively referred to herein as 'The Company,' 'We,' 'Us,' or 'Circle'), place paramount importance on safeguarding the privacy and security of personal information ('Personal Data'). Circle by CRED is a private access layer designed to restore connection and perspective. We prioritize the establishment and maintenance of Your trust. This Privacy Policy applies to all individuals actively serving as an Expert (or 'Resident') on the Circle mobile application. The Residents shall (hereinafter be referred to as 'You', 'Your' or 'Resident(s)'). As a Resident, You entrust Us with Your sensitive professional and financial data, and We entrust You with the sensitive context of our users. To clarify, we are not responsible for any information, personal or otherwise, shared by the Users with You or by You with Users directly or through any means not expressly supported by the App.
Collection of information
To maintain complete traceability and platform integrity, We collect the following 'Resident Information':
- Identity & Contact Data: Your full legal name, a valid email address, phone number, PAN Card details, location, any photographs or videos You upload, and tax residency for identity verification and administrative communications.
- Professional Credentials: Your selected area of Residence, a PDF resume, a valid LinkedIn URL, and Your professional licenses and certifications (including educational) to validate Your expertise.
- Social Profiles: Links to Your website, Instagram, X (Twitter), and YouTube profiles.
- Financial Details: Bank account details, GST details (if applicable), and billing/invoicing address for payout processing.
Utilization of information
We collect, process, and store Your information only as required to provide and improve our services. Specifically, We may use Your data for the following purposes:
- Verification & KYC: To shortlist appropriate Residents and verify all Residents meet our quality and legal standards.
- Enabling continued access: To create and maintain Your profile and manage marketing assets.
- Payment verification: To facilitate seamless transfers of Your earnings to Your bank account.
- Platform Analytics: We utilize third-party tools to track user events, including application starts, video assessments, file uploads, and errors, to manage and improve the app.
- Communications: To send You application notifications, status updates, automated reminders, and promotional content related to the app.
- Service Quality: To review session recordings for dispute resolution and quality assurance.
Disclosure and sharing of data
We maintain strict controls over who can access Your professional and onboarding data. We may disclose or share Your information in the following specific scenarios:
- Third-Party Service Providers: Any information or data collected from You may be shared with third parties for further processing for the Purpose set out above. Circle utilizes third-party tools to track user events, including application starts, video assessments, file uploads, and errors. We also utilize Artificial Intelligence (AI) tools to generate automated chat summaries and to provide real-time video enhancement services. You consent to Your data being processed by these third-parties for analytics and application management purposes.
- Law Enforcement & Legal Safety: In case required under law or under the instruction of any regulatory authority, Circle may need to share your personal data with regulatory authorities, government agencies (including internal disciplinary committees), and law enforcement authorities. You acknowledge that Circle shall have the right to report any possibly illegal content to relevant law enforcement authorities.
Your role in handling user data & confidentiality
As a Resident, You will have access to specific user-generated content to facilitate Your services. You shall handle all such user information in a confidential capacity and are required to use it solely for providing the agreed services, which comes with strict obligations:
- What You Receive: You will have access to all the user-uploaded consultation files (images, PDFs, etc) and AI conversation summaries of Your sessions.
- What is Withheld: Personal Data such as the user's phone number and email rests solely with Circle and is not shared with You.
- Strict Communication Rules: You are strictly prohibited from requesting or capturing a user's direct contact information (Phone/Email) during a session. All communication must happen through the Circle interface.
- Non-Disclosure: You must not download, record, or share user transcripts, audio, or video recordings outside the Circle platform.
- Privacy by Design: You must make sure Your environment is private during video/audio calls to protect user confidentiality.
Your rights & controls
In accordance with applicable laws, You have the right to:
- Access & Correction: Review and update Your bank details or certifications via Your Resident Dashboard.
- Account Deletion: Request to de-register from the platform. Upon deletion, We may retain certain information for a reasonable period as necessary to fulfill the purposes outlined in this Policy or as mandated by legal and regulatory obligations.
- Withdrawal of Consent: You may revoke / modify consent to Circle at any time by going to Your account settings, though this may result in the inability to provide services on the platform.
Retention
Upon successful OTP verification for the application, all entered data shall be saved as a draft for up to 90 days to allow You to resume an incomplete application. All other Personal Data will be retained only for the duration necessary to fulfill the purposes elucidated in this Privacy Policy, unless a longer retention period is necessitated by law or for directly related legitimate business purposes. Once the Personal Data is no longer required, it will be disposed of securely.
Security practices
We are committed to preserving the integrity of your Personal Data and maintaining its accuracy. We adopt reasonable physical, administrative, and technical safeguards to protect your Personal Data from unauthorized access, use, and disclosure. We implement industry-standard security measures to protect Your sensitive financial and professional data. This comprehensive security and privacy design allows us to defend our systems from potential threats. More details regarding our security practices can be found
here. If you identify a potential security vulnerability in Circle's products, please report it to us responsibly. Kindly submit a detailed bug report, including steps required to reproduce the vulnerability, to us at security@cred.club. We pledge our best efforts to investigate and rectify legitimate issues within a reasonable timeframe while requesting you not to disclose it publicly.
Grievance redressal
In the event of any concerns regarding your experience with Circle, reach out to us via our support channels
here. If your issue remains unresolved, you can escalate it to our grievance officer (Mr. Atul Patro) by clicking
here.
Dispute resolution and governing law
This policy is governed by the laws of India. Any dispute arising out of or related to Circle Resident App shall be subject to the dispute resolution mechanism set out in the
Terms of Use of the Circle Resident App.
Modifications to this policy
We reserve the right to amend this policy at our discretion. Continued use of the App following any changes constitutes acceptance of the modified Privacy Policy.