Other Covered Entities

Circle Payments, LLC


  • Financial Services
  • Banking


EU-U.S. Data Privacy Framework Framework: Inactive - Lapse

Original Certification Date: 11/2/2016
Inactive Start Date: 11/29/2020

Purpose of Data Collection

Circle collects customer's name, address, phone number, email, birth date, password, and tax identification number (if applicable). Circle also collects card number or IBAN/BIC numbers and related account information if the customer would like to link a debit card, credit card or current account. Circle may also request government issued photo ID and a "selfie" to verify customer identity or to meet legal and regulatory obligations. When that is necessary, the customer will be prompted to provide such information. The following information is collected automatically: Device Information Location Information Contacts Photos, Videos & Other Media Message Content Transactions Cookies Circle collects personal information on its customers so that we can provide a safe and seamless way to make and receive payments. The information we collect allows us to: Deliver the full range of payments and functionality of the Circle product; Keep in touch with customers - whether it be for providing customer service, notification regarding new features that have been added to the mobile apps, or providing security notices or information; Verify customer?s identity to prevent fraud or unauthorised activity and meet BSA/AML obligations; Improve Circle or add new product features by analysing usage trends; Personalise the Circle experience by matching product features to targeted interest areas; and Fulfill any other purpose for which the information was collected. Circle will never sell or rent personal information to third parties, however we may combine personal information with information we collect from other companies and use it to improve and personalise the Services, as well as our content and advertising. Banking partners to process payments Third party identity verification services to prevent fraud and meet BSA/AML obligations Service providers that help us analyse how people are using the app Law enforcement or government officials when compelled to do so by a specific regulation, subpoena, court order or formal request, or we otherwise believe in good faith that we need to share such information to prevent physical harm, financial loss, or are obligated to report illegal activity. Third party financial, technical and legal auditors of Circle?s operations If Circle merges with or gets acquired by another Company, they will have access to the personal information. If this happens, Circle will require that the new entity follows this Privacy Policy and will notify customers of any such change. Circle UK Trading Ltd. (a U.K. entity), Circle Internet Financial Trading Company Limited (an Irish entity) and other Circle affiliated entities as necessary in order to provide the best possible product and customer support. Circle will share personal information with other third parties if the customer specifically authorizes us to do so.

Dispute Resolution

Questions or Complaints?

If you have a question or complaint, please contact Circle Internet Financial, Inc. at:

Mark duBose
Chief Compliance Officer
Circle Internet Financial, Inc.
Circle Internet Financial, Inc.
99 High Street, 17th Floor, Suite 1701
Boston, Massachusetts 02110

Appropriate statutory body with jurisdiction to investigate any claims against Circle Internet Financial, Inc. regarding possible unfair or deceptive practices and violations of laws or regulations covering privacy Federal Trade Commission