Circle Hood Technologies Ltd (CHTL) Privacy Policy

This is the Privacy Policy as it appears in the Terms and Conditions:

1.  We are Guided by GDPR

a. The General Data Protection Regulation (GDPR) came into force across the European Union on 25-May-2018.

b. All data will be collected, stored and processed by CHTL in accordance with the European Union GDPR No. 2016/679.

c. Under GDPR, all activities involving the processing of personal information are undertaken under one or more of 6 legal grounds for processing as described in GDPR, Chapter 2, Article 6(1). By registering and using CircleHood you agree to CHTL storing and using all data you provide us with for the purpose of running the business of CircleHood including and not limited to sharing anonymised content such as events and Listings on other Social Media (e.g. Instagram) belonging to CHTL.

d. Pursuant to GDPR Chapter 5, CHTL will not sell, lease or share your data unless it is required by law to do so or where you have explicitly agreed to such actions.

e. The services offered by CHTL, including but not limited to personalised content, via CircleHood can only function if CHTL collects, stores, transfers, deletes and/or otherwise uses and processes specific data relating to CircleHood’s Users. Therefore, pursuant to GDPR Chapter 2, Article 7 and GDPR Chapter 2, Articles 6(1)(b) and 6(1)(f), CHTL is entitled to collect and process personal information. In addition, and in line with GDPR Chapter 2, Article 7, all Users have the ability to withdraw their consent by following the procedure described in Section 13 of this User Agreement. Furthermore, with regard to other services (e.g. newsletters) Users will always be asked to opt-in and will always be able to unsubscribe to such services with ease.

f. Certain services on our Platform are offered by third-party suppliers. When you use these services, the data protection regulations of these suppliers will then apply in addition to this data protection statement. Prior to your use of such services, the respective suppliers may require you to provide an additional permission to store and use your data under data protection law. Users will not be able to use such service providers through CircleHood unless they register as Users both on CircleHood and, if necessary, on the supplier platform.

g. With regard to data retention, guided by GDPR, Chapter 2, Article 5, CHTL will not keep any data it collects for a period longer that is needed.

h. With regard to the rights of the data subject (i.e. a User), guided by GDPR, Chapter 3, CHTL will ensure Users retain their rights to their data namely: be informed on what is collected and why, have access to their data, be entitled to ask for their data to be corrected, ensure that their data gets deleted where possible by law, restrict and stop the usage of their data.


2. Why CHTL collects data?

a. CHTL will collect and process certain data elements to provide services available in CircleHood enabling the usage of this User Agreement. Specifically:

  • For identify verification and personal information protection.

  • For listing, buying and selling items.

  • For facilitation of communication between Buyers and Sellers.

  • For facilitating electronic payments between CHTL, Buyers and Seller.

  • For sending messages relating to services, current and past transactions.

  • To help you locate items and events near you, boost local trade and sense of community.

  • To comply with local tax laws and the general safety of our Users.

  • To help mitigate fraud and any unlawful activity, help resolve any disputes and technical issues aiming for a fault-free and secure platform where CHTL’s Terms and Conditions could be enforced.

  • To increase trust between CircleHood Users by constructing “trust score” which will be reflected in User’s Ratings, accounting for transactions (both as a Buyer and a Seller), fair pricing, accuracy of listings, response time to other Users.

3. What data does CHTL collect?

a. When using CircleHood, CHTL process the following data (log-files), whether a User is logged in or not to CircleHood as a registered member:

  • The IP address of your device.

  • The browser used by your device.

  • The content and URLs you connect to.

  • The date and time of your connection.

  • The model and manufacturer of your mobile device.

  • The operating system used by your mobile device (iOS, Android).


b. When registering with CircleHood all Users have to confirm that they are at least 18 years’ old.

c. All registered Users are required to set a password to their account. The password will be encrypted and then stored and CHTL will not able to read/decrypt it. Should a User forget or wish to reset their password, they must use the facility provided within CircleHood. As a reminder, password and account information are personal and must not be shared. It is also highly recommended to logout of CircleHood when not using it. Users are also reminded that transfer of data via the Internet is not always totally secure (e.g. when using public WiFi) and could be accessed by 3rd-parties.

d. If a User registers via their Facebook account, they will be transferred from CircleHood to Facebook and asked to enter their Facebook login details. While CircleHood could access all public information available on Facebook, CHTL will only use and store the following:

  • Profile photo

  • First name

  • Surname

  • Email address


e. If a User registers with email only (i.e. not Facebook), CHTL will only ask for:

  • Member username (mandatory and will be publicly displayed on your CircleHood profile).

  • Email address (mandatory).

  • Password (mandatory).

  • Post code (optional).

  • About you (optional).

f. Post registration you may provide additional information via CircleHood’s settings function:

  • Profile photo (will be publicly displayed on your CircleHood profile). 

  • First name and surname (optional)

  • Gender (optional)

  • Date of birth (optional; month and year only)

  • Address (only used for shipping; you can arrange for a different location for collection)

  • About you (optional)

  • Information about your kids (optional)

g. When setting up the MANGOPAY e-Wallet (required for processing credit card, debit card and PayPal payments), CHTL will require the following:

  • Full name

  • Date of birth

  • Invoice address

  • Telephone number

  • Email address

h. Payment via MANGOPAY

  • If you use the MANGOPAY electronic payment system, MANGOPAY will collect the payment information required according to the payment method selected (e.g. credit card, PayPal). Payment will then be implemented via MANGOPAY and the payment service provider you have selected (e.g. PayPal). To this extent, the data protection regulations of MANGOPAY and the relevant payment service provider will apply. If you use a credit card as your payment method, CHTL will see only the last four digits of your card number. This information will be used by us solely for the purpose of confirming payment and preventing fraud.

i. Other data

  • Messages sent through CircleHood chat facility, comments posted on the Wall and post transaction reviews

  • Location data made available by your device and with your consent.

4. Cookies

a. CircleHood does not use cookies as it is an app.

b. CHTL’s website,, does not use cookies, however, our website hosting provider may use their own cookies (third-partycookies). Users and site visitors are free to accept or reject these cookies.

5. Data Retention

a. Unless stated otherwise on this data protection statement or provided for by statute, CHTL will save:

  • All personal data not needed for the enforcement of this User Agreement for 30 days from the date of its collection.

  • All personal data available on CircleHood in case of suspension following a violation of this User Agreement for a minimum of 2 years to ensure the security of our platform and our users pursuant to GDPR Chapter 2, Articles 6(1)(d and f).

  • All transactional data (sale agreements between a Buyer and a Seller) for a minimum of 6 years from the end of CHTL’s financial year as required by the UK tax law. This also protects CHTL’s rights and interests in case a chargeback dispute against CHTL or its Users pursuant to GDPR Chapter 2, Articles 6(1)(c to f).

  • All other personal Data specified in this policy for 3 months from the date of deletion of your User Account or for 3 months after 5 years of inactivity on your account or from the moment your account has been blocked/suspended in case you have violated this User Agreement. 

  • CHTL may remove any open and inactive listings if they have been inactive for 6 months or more.

  • CHTL may store personal data longer than any time period mentioned above to the extent that this data is necessary for compliance with local legal obligations, in particular statutory retention periods, and for the establishment, exercise or defence of legal claims.

6. Securing User Data

a. We use security measures, including physical, administrative, and technical safeguards to protect the confidentiality of all User data. These measures include encryption, security certificates, access controls, information security technologies, policies, procedures and other information security measures to help protect your Information.

b. Where possible, CHTL will anonymise information so that Users cannot be identified from it.

7. User’s Data Rights

a. Under GDPR, Chapter 3 provisions, Users have the right at any time:

  • To be informed of the data CHTL collects and processes and to demand a copy of it (right to be informed). 

  • To demand the correction of inaccurate data (right to rectification). 

  • To have access to and amend by themselves any data, except sent messages, forum posts, reviews and closed listings, in their CircleHood account (right to rectification). 

  • To request, subject to just cause, for their account to be deleted and associated data to be deleted (right to deletion).

  • To request restriction of the processing of their data, provided the statutory criteria are met (right to restriction of processing).

  • To be subject to decision-making not wholly reliant on automated processing, unless the statutory conditions for such automated decision-making are met (CircleHood does not currently operate automated decision-making).

  • To object the processing of data (right to object) except where the processing is based on a task carried out in the public interest or in the exercise of official authority vested or legitimate interest pursuant to GDPR Chapter 2, Articles 6(1)(c to f).

  • To withdraw at any time any permission you have provided as part of registering or using CircleHood. Such withdrawal will not affect the lawfulness of data processing carried out prior to the withdrawal. Such withdrawal may require a User to request for their account to be deleted (right to erasure).

  • You can withdraw your permission for the sending of any CircleHood newsletters you have subscribed to by clicking "unsubscribe" at the end of the Marketing Email.


b. To exercise any of the rights specified in this section, or if you have any queries regarding the processing of your data as part of your use of the CircleHood, please contact our data protection officer at Regardless of any other legal remedy, you also have the right at any time to submit a complaint to the supervisory authorities.