Privacy Policy

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Last updated: July 9, 2026

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Live Circle takes your privacy seriously. This Privacy Policy (“Policy”) describes the types of personal data Live Circle collects from and/or about you when you a) visit or use our Live Circle Community platform, including our website, mobile applications, and related features and services (collectively referred to as the “Platform”) or b) visit our company website (referred to as the “Website”). This Policy details our practices for collecting, using, maintaining, protecting, and disclosing that data.

This Policy applies to any information relating to a natural person who is, or can be, identified either directly or indirectly from such information, and includes information such as a person’s name, address, telephone number, email address, Internet activity (such as browsing history), or other information directly linked to that person (“Personal Data”). You are not legally required to provide Personal Data to us, but if you decide not to provide such information, we may not be able to register you to use the Platform.

Live Circle reserves the right, in its sole discretion, to modify this Policy at any time by updating the locations where it is posted or referenced on the Platform or Website. We will update the “Last updated” date at the top of this Privacy Policy when any updates are made. You should periodically review this Policy, so you are aware of any such revisions. Your continued use or access to our Platform or Website constitutes your agreement to the revised Privacy Policy, terms, notice, and disclosures.

We collect Personal Data in two primary ways: (1) when you voluntarily provide Personal Data to us; and (2) automatically when you visit our Website or use the Platform.

To use our Services, you will have to upload Personal Data onto our Platform.

First, you must provide Personal Data to us in order to register for an account. During registration, we request Personal Data about you, including, but not limited to:

• Your name and contact information;
• Your date of birth;
• Your address; and
• A username.

Once you are registered, your use of the Platform will inevitably involve the provision of additional Personal Data. By means of example, Personal Data may be included in:

• Audio recordings, transcripts, and summaries of phone calls you carry out over the Platform
• Information contained within email and text communications you send and receive via the Platform
• Documents that you upload to the Platform
• Comments and calendar information you post through the Platform
• The log of all calls you place and receive using the Platform
• Images and videos you post through the Platform
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It is important to note that all calls placed using the Platform will be recorded and transcribed as part of Live Circle’s Services. Live Circle’s Services also involve summarizing email and other written communications which take place via the Platform. Accordingly, you should have no expectation of privacy relative to the individuals in the Community of which you are a guest when you are communicating via the Platform.

For purposes of this Policy, all information and Personal Data you upload to or provide via the Platform is referred to as “Content”. Though we have no initial control over what is contained in your Content, there is a strong likelihood that some of the Content you upload will include Personal Data, personal health data and financial data.

Please note that it’s essential to ensure that any Content relating to children under the age of 13 (or such legal age as applies in your country) is not uploaded without parental consent. Remember, we do not control what you initially decide to upload onto our platform, so if you upload such Content, you will remain fully responsible for obtaining (and being in a position to show that you obtained) such consent. We will not knowingly collect such Content on your behalf.

We are fully aware that such data is subject to specific laws and regulations, and we have set up our business and operations with those in mind. In some cases, your Personal Data may include health and/or medical information that may constitute protected health information (“PHI”) under the U.S. Health Insurance Portability and Accountability Act of 1996 and its implementing regulations (“HIPAA”). Live Circle will use, disclose, and protect PHI only as permitted or required by HIPAA and Live Circle’s business associate agreements with covered entity health care providers with whom you have a relationship (to the extent applicable).

We also automatically collect certain Personal Data about you when you interact with our Platform or Website. For example, we use website analytics tools on our Platform and Website to retrieve information from your browser, including the website you came from, the search engine and the keywords you used to find our Platform or Website, the pages you view within our Platform or Website, your browser add-ons, and your browser’s width and height. We may also use technologies, such as cookies, to collect information about the pages you view, the links you click and other actions you take on our Platform or Website. Additionally, we collect certain standard information that your browser sends to every website you visit, such as your IP address, browser type and language, access times and referring website addresses. For additional information, please refer to our Cookie Policy. Although some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities, at this time we do not honor such signals.

You have the option to choose to disable certain cookies used on our Platform or Website which are not strictly necessary. Refer to our Cookie Policy for additional information.

To help us deliver a safe, personalized, and effective experience on our Platform, you agree to let us use your Personal Data for the following purposes:

• Service delivery and performance – To operate, maintain, and improve our Platform, including ensuring technical functionality, account management, and customer support.
• Personalized insights – To provide tailored suggestions, insights, and recommendations that are relevant to your life journey, based on your preferences, activity, wellbeing, and input. This can include making you aware of or recommending our products or services, or those of third-party vendors.
• Wellbeing – To support your personal wellbeing goals over time.
• Platform improvements and innovation – To analyze usage patterns, enhance functionality, test new features, and develop future services.
• Legal and compliance reasons – To comply with applicable laws and regulations, respond to legal requests, and enforce these Terms.
• Research and analytics – To create anonymized, aggregated datasets that help us understand trends, user behavior, and product effectiveness. These insights help us make evidence-based improvements but cannot be used to identify you.

We may also use your Personal Data to create aggregated and/or de-identified data and use such data for any legally permissible purpose, including to train our AI technologies. We may also disclose to third parties aggregate or de-identified data that is not personally identifiable for any legally permissible purposes without restriction.

We only use your Personal Data for the purposes described here. If we ever want to use it for something substantially different, we’ll ask for your explicit permission first. To the extent applicable, if HIPAA or our business associate agreements impose additional restrictions on our uses and disclosures of PHI, we will comply with such restrictions.

We know that your data is very important, and we understand that you are entrusting us with it for the specific purpose of using the Services. With that in mind, and given the nature of the data involved, we want you to give us your clear consent to allow us to use it, safe in the knowledge that you can change your mind at any time. The terms below help us achieve that.

By using the Services, you agree that we may collect, use, store, and share your Personal Data, including sensitive Personal Data such as health-related information, so that we can provide, maintain, and improve the Services. This may include processing Personal Data to offer personalized experiences, generate insights, or deliver relevant prompts and suggestions. Where necessary before using certain components of the Services, we will seek your additional consent within the Platform.

Some of this information may be generated or interpreted by AI. We use this information to support your wellbeing, but it is not intended to replace professional medical advice or care (see the Not Medical Advice section of the Platform’s Terms of Use for more information), nor financial or legal advice, to the extent that any is given.

To provide key features of the Services, such as personalized wellness suggestions, we may need to process sensitive Personal Data (including health-related information). You explicitly consent to us collecting and using this information to deliver the functionality of the platform.

You can adjust how much Personal Data you choose to share, or allow us to process, by managing your settings in your account in the Platform.

By uploading, entering, or otherwise submitting any Personal Data or Content to the Platform (including, where relevant, activity logs, health information, entries, preferences, or other inputs), you grant us a worldwide, non-exclusive, royalty-free, transferable, sublicensable license to use, host, store, copy, display, reproduce, adapt, modify, analyze, translate, publish, and create derivative works from your data, solely for the purposes of providing and improving the Services (subject, if applicable, to HIPAA and our business associate agreements with health institutions and healthcare professionals).

To be clear, this license allows us to carry out the activities required for the purposes set out in the Purpose of data collection and use section above.

We will never sell your Personal Data.

This license continues for as long as your Personal Data is stored on our systems in accordance with our retention practices, or until you delete your account and associated data or request that we delete all Personal Data we maintain about you (to the extent your jurisdiction affords you the right to make such request), whichever comes first, except where we are legally required to retain it.

Remember, as a Member, this license allows us to provide the Services to you, as set out in the Terms of Use. For Guests, allowing us to use your Personal Data in this way means that we can provide the Services to the Member who invited you to their join their Community.

By accessing our Platform, you have provided your consent to us to allow us to do certain things. Regardless of the issues at hand, you are free to revoke that consent at any time via the Services, and we will adapt our provision of the Services on that basis, to the extent that we can.

In the context of your continued use of the Platform, if you eventually revoke a consent which ultimately prevents us from delivering the Services, we will inform you of that fact and ask you to confirm whether you want to continue using the Services or cancel your account.

We will only process your Personal Data in accordance with applicable laws, including relevant data protection and consumer protection laws, and our contractual arrangements that apply in the context of your use of the Services.

We limit how we disclose your Personal Data, including health-related data, to others and we want you to know specifically how and why we do that.

We do not sell or share your Content or Personal Data to third parties for commercial purposes without your express consent. That includes advertisers, data brokers, or any other external parties who want to use your information for their own purposes.

We only disclose your Personal Data in the following cases and only to the extent necessary:

• To provide the Services: We work with trusted third-party providers (like cloud storage, analytics tools, communication platforms, and infrastructure services) to help us operate, improve, and secure the Platform. These providers are bound by rigid terms and confidentiality obligations and are only allowed to use your Personal Data as instructed by us.
• As you direct: If you are a Member, you can choose which of your Personal Data is disclosed with whom in your Community. We will facilitate your choices through the Platform.
• With your consent: If we ever want to disclose your Personal Data for a reason not covered in these Terms or our Privacy Policy, we’ll ask for your explicit permission first.
• For legal reasons: We may disclose your Personal Data if we reasonably believe it’s necessary to comply with the law, respond to a valid legal request, protect the safety of someone, prevent fraud, or enforce our Terms of Use.
• As part of a business transition: If our company is involved in a merger, acquisition, asset sale, or similar event, we may transfer your Personal Data to the new entity, but we’ll ensure your rights are still respected.
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At Live Circle, we understand the importance of transparency and one way we show it is by ensuring that you have control over your Personal Data. The legal rights you have in this regard will vary, depending on the nature of the Personal Data you entrust us with and where you live. However, regardless of those factors, we offer you the rights set out below, even when the law does not necessarily require them.

Accordingly, as a Member and Guest, you have the following rights under this Policy:

• Access your Personal Data – You can ask us for a copy of the Personal Data we hold about you.
• Correct your Personal Data – You can request that we fix any inaccurate or incomplete Personal Data.
• Delete your Personal Data – You can ask us to delete your Personal Data, either in part or entirely (for example, by closing your account).
• Object to or limit how we use your Personal Data – You can ask us to stop or restrict how we use your Personal Data in certain circumstances, as detailed in this Policy.
• Transfer your Personal Data – You can request to receive a copy of your Personal Data in a structured, machine-readable format, and in some cases ask us to send it to someone else.
• Withdraw your consent – If we’re processing your Personal Data based on your consent, you have the right to withdraw that consent at any time, as detailed in the Consent to Data Use and Licensing section above.

When using the Services, you can exercise most of these rights through your account settings. Otherwise, in all cases, you can contact us directly at support@livecircle.com. Please note that in some cases, we may need to verify your identity or ask for additional information before processing your request. This is to help protect you and prevent fraudulent requests.

In rare cases, local laws may prevent us from complying with these rights (for example, we may be required by law to keep certain Personal Data), but we’ll always explain why if that’s the case.

We take the security of your Personal Data seriously and use a combination of technical and organizational measures to help protect it. These measures are designed to reduce risk of unauthorized access, disclosure, alteration, or destruction of your Personal Data while it’s stored with us or being transmitted.

This includes steps like:

• Encrypting your Personal Data;
• Secure server environments;
• Access controls and internal policies for Personal Data handling.

However, no system is completely secure, and we want to be clear about that. Transmitting information over the internet or storing it electronically always carries some level of risk. While we do our best to protect your Personal Data, we can’t guarantee that unauthorized access, hacking, or other breaches will never occur.

If an incident involving your Personal Data warrants it, we’ll notify you in accordance with the specific laws which apply to data breaches.

You also play an important role in keeping your information secure and, when using the Services, the Account registration section of our Terms of Use highlights ways you can play your part.

If you are a resident of a U.S. state that has enacted a consumer health data privacy law, please refer to our Consumer Health Data Privacy Notice.

If you provide your mobile phone number and opt in, we may send you text messages related to the Services (for example, account, coordination, or appointment-related messages).

• Message frequency varies. Message and data rates may apply.
• Reply STOP to unsubscribe at any time, or HELP for help.
• Carriers are not liable for delayed or undelivered messages.
• No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Mobile opt-in data and consent are never shared with any third parties.

If you have any questions about this Privacy Policy, or if you would like to exercise any of your data rights, please contact us at support@livecircle.com.