CircularX Shop — Privacy Policy

Effective Date: February 14, 2026

This Privacy Policy explains what personal and non-personal information CircularX Shop (“we”, “us”, “our”) collects, how we use it, when we share it, and the choices you have. It applies to our mobile applications, websites, APIs, and other services that link to this policy (collectively, the “Service”).

Note: this policy is intentionally detailed — read the sections that apply to you (buyer, seller, visitor, or developer). If you have an account, you can view and manage most preferences and requests directly from your account settings or the app’s privacy dashboard.

1. Key definitions

Personal Data: information that identifies or can reasonably be linked to an identifiable person (e.g., name, email, phone, payment details).
Non-Personal Data: aggregated or de-identified data that cannot reasonably be used to identify an individual.
Process / Processing: any operation performed on data (collect, store, use, analyze, delete).
Controller / Processor: where applicable, we act as the controller for user data we collect for our operations; third-party service providers may act as processors.

2. What data we collect (categories)

We group data into categories to keep things clear.

A. Account & identity data

Full name, username, profile picture, birth year (where required), and account identifiers.

B. Contact & transactional data

Email address, phone number, billing & shipping addresses, order history, invoices, refunds, and transaction records.

C. Payment data

Payment instrument identifiers as needed to process payments (e.g., last four digits, tokenized payment IDs). Full payment card numbers are processed by our payment processors and are not stored on our servers except for secure tokens.

D. Device & usage data

Device model, operating system, app version, unique device identifiers, IP address, browser type, language, screen size, and crash / diagnostic logs.

E. Location data

Approximate location derived from IP address; precise location only if you enable location services in the app.

F. Communications & support

Customer support messages, call recordings if you call support (where legally permitted), chat logs, dispute messages, and feedback.

G. Content you provide

Product descriptions, photos, reviews, Q&A, seller listings, messages between users, and any files you upload.

H. Automated & derived data

Behavioral and preference signals (searches, clicks, time on page), recommendation model outputs, fraud scores, shipping estimates.

3. How we collect data

Directly from you: when you register, purchase, list an item, message, or contact support.
Automatically: when you use the Service (cookies, logs, analytics).
From third parties: payment processors, shipping carriers, identity verification services, social login providers, advertising partners, or public sources.

4. Legal bases for processing (where applicable)

For users in jurisdictions requiring legal bases (e.g., GDPR):

Contract performance: to process orders, provide services, send confirmations, and manage accounts.
Legitimate interests: fraud prevention, security, product improvements, analytics, preventing abuse, and enforcing our terms. We balance these interests with your privacy.
Consent: for optional marketing communications, cookies beyond strictly necessary, or certain profiling. Where required, we obtain explicit consent.
Legal compliance: to meet our legal obligations (tax records, law enforcement requests).

5. Primary purposes for which we use data

We use your data to:

Provide, maintain, and improve the Service (orders, listings, search, recommendations).
Process payments, refunds, and billing.
Communicate about orders, changes to the Service, and security notices.
Personalize content and show relevant offers, search results, and ads (where you permit).
Authenticate and secure accounts and detect fraud or abuse.
Facilitate returns, warranties, and dispute resolution.
Conduct analytics, research, product development, and business operations.
Comply with legal or regulatory obligations.

6. Sharing & disclosure

We share information in limited circumstances:

With service providers & partners

Payment processors, shipping and fulfillment partners, cloud hosting, analytics providers, CRM and helpdesk vendors, identity verification, and advertising platforms — strictly to provide our Service and in accordance with contracts that require confidentiality and restrict use.

Between users

Seller and buyer contact info (shipping address) is shared as necessary to fulfill orders. Reviews and public listings you post are visible to other users.

For legal reasons

When required by law, to respond to lawful requests from authorities, or to protect the rights, property, or safety of our users and the public.

Business transfers

In connection with any merger, sale, financing, acquisition, or transfer of assets; data may be among the transferred assets. If such a transfer occurs, we will aim to notify affected users.

Aggregated/De-identified data

We may share aggregated usage statistics that do not identify individuals for research or commercial purposes.

We do not sell personal data for other companies’ direct marketing unless you give explicit consent (we will always disclose material sharing under privacy dashboards where required by law).

7. Cookies, tracking, and advertising

We use cookies, local storage, web beacons, SDKs, and similar technologies to operate and optimize the Service, remember preferences, analyze trends, and deliver relevant content.
Advertising partners may set cookies or use device identifiers. You can manage cookie preferences via the app settings or your browser.
Opting out of targeted advertising may limit personalization but will not prevent essential service features.

8. Analytics, profiling & automated decisions

We use analytics and machine learning to power search ranking, recommendations, dynamic pricing suggestions for sellers, and fraud detection. Some systems generate automated decisions (e.g., risk flags) which can affect order approval or account restrictions.
If an automated decision has a material effect on you, you may request a review through your account tools.

9. Data retention

We keep personal data for as long as necessary to provide the Service, comply with legal obligations (tax, accounting), resolve disputes, and enforce agreements. Retention periods vary by data type (transaction records are retained longer than ephemeral analytics logs).
When data is no longer required, we delete or irreversibly anonymize it, unless retention is needed for legitimate business reasons or legal obligations.

10. Security

We implement industry standard technical and organizational measures: encryption in transit, limited access controls, logging, regular security testing, and third-party security audits.
No system is 100% secure — if a security incident affects your data, we will promptly evaluate and notify users and regulators as required by law.

11. International transfers

The Service is global; data may be processed or stored in countries outside your jurisdiction. We use appropriate safeguards for such transfers (e.g., contracts incorporating standard data protection clauses, approved frameworks, or other lawful transfer mechanisms).

12. Minors

The Service is intended for users 18+ (or the age of legal majority in your jurisdiction). We do not knowingly collect personal data from children under the applicable age. If we learn we have collected data from a child, we will delete it as required by law.

13. Your privacy choices & rights

You can exercise privacy choices directly via the app and account settings:

Access & portability: view the personal data you provided and download a copy using in-app tools.
Correction: edit inaccurate profile, shipping, or listing information via account settings.
Deletion: you can request account deactivation or deletion through the account settings or privacy dashboard; some transactional records may be retained for legal reasons.
Marketing opt-out: manage marketing preferences in your profile settings.
Cookie & tracking controls: use the cookie preferences dialog, mobile OS settings, or browser privacy settings.
Object / Restrict processing: where law permits, you may object to or request restrictions on certain processing activities; use the in-app privacy tools to submit a request.
Complaint: you may lodge complaints with a relevant supervisory authority where applicable.

If you require further assistance beyond the in-app controls, use the built-in support request features in the Service (e.g., support ticket forms, in-app help center).

14. Third-party sites & services

The Service may link to or embed third-party services (payment gateways, social logins, marketplaces). These third parties have their own privacy policies and practices — review them before use. We aren’t responsible for their privacy practices.

15. Changes to this policy

We may update this policy from time to time (e.g., to reflect legal changes or new features). Material changes will be posted in the app and, where required by law, we will obtain consent or provide notice. Check the “Last updated” or “Effective date” at the top for the most recent version.

16. Enforcement & legal

We comply with applicable privacy laws (as applicable by jurisdiction). Where we are a data controller, we will respond to lawful requests from competent authorities in accordance with applicable processes.

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