Last Updated:
October 19, 2025
The Circle ("Investors Circle LTD.," "we," "us," or "our") operates in Ontario, Canada, and is committed to protecting your privacy. This Privacy Policy outlines how we collect, use, disclose, and safeguard your personal information, ensuring compliance with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and Canada's Anti-Spam Legislation (CASL).
This Policy is structured around the 10 Fair Information Principles mandated by PIPEDA.
We are responsible for the personal information under our control. We have designated a Privacy Officer who is accountable for our compliance with this Policy and applicable privacy laws.
Contact Information:
Attn: Privacy Officer
The Circle, Investors Circle LTD.
49 Wellington St. East, Suite 500
Email: contact@theinvestorscircle.ca
We identify the purposes for which personal information is collected at or before the time of collection. These purposes include:
We obtain your meaningful consent for the collection, use, or disclosure of your personal information, except where authorized or required by law.
We limit the collection of personal information to that which is necessary for the purposes identified.
Payment details are collected and processed directly by our third-party processor, Stripe. We do not store your full credit card details.
We do not sell, rent, or trade your personal information. We may share information with trusted third-party service providers under strict confidentiality agreements:
We may also disclose information if required by law or during a business transfer (e.g., merger or acquisition).
We retain personal information only as long as necessary to fulfill the identified purposes or as required by law (e.g., tax record-keeping).
We are based in Canada. However, some service providers (like Stripe, hosting services, or email providers) are located in or process data in the United States or other countries.
As a result, your personal information may be transferred, processed, and stored outside of Canada. While outside of Canada, your information is subject to the laws of the country in which it is held (e.g., the USA PATRIOT Act), and may be accessible to the government, courts, or law enforcement agencies of that country. We use contractual measures to ensure our service providers protect your information in a manner consistent with Canadian privacy laws.
We strive to ensure your information is accurate and up-to-date. You can update your information through your account settings.
We use appropriate physical, organizational, and technological safeguards to protect your information from unauthorized access, use, disclosure, or destruction. These measures include SSL encryption, access controls, and secure hosting environments. However, no method of electronic storage is 100% secure.
We make information about our policies and practices readily available. This Privacy Policy is accessible on our website.
We use cookies and similar technologies (like pixels in emails) to ensure the website functions correctly (e.g., login sessions) and to analyze website traffic and newsletter performance. You can control cookies through your browser settings, but disabling essential cookies may impair website functionality.
You have the right to access and correct the personal information we hold about you. To request access, please contact our Privacy Officer in writing. We will respond within 30 days, subject to any legal exceptions.
You have the right to challenge our compliance with this Policy. Please contact our Privacy Officer with any complaints. We will investigate and respond. If unsatisfied, you may contact the Office of the Privacy Commissioner of Canada.
We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new Policy on this page and updating the "Last Updated" date.