Last updated: August 10, 2026
RE:CIRCLE Ontario, LLC (“Company“, “we“, “our“, or “us“) respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes how we collect, process, retain, and disclose personal data about you when providing services to you through our website and services that link to this policy (our “Services“) and our practices for using, maintaining, protecting, and disclosing that information. This policy applies only to information we collect through the Services and in communications, including email, text, chat, and other electronic messages, between you and the Services. It does not apply to information collected by us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries) or any third party (including our affiliates and subsidiaries), including through any application or content that may link to or be accessible from or through the Services.
Please read this policy carefully to understand our policies and practices regarding your information and how we treat it. By interacting with our Services or providing us with your information, you agree to the collection, use, and sharing of your information as described in this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Services after we make changes as described here is deemed to be acceptance of those changes, so please check the policy periodically for updates.
Children’s and Minors’ Data
Our Services are not intended for, and we do not knowingly collect any personal data from, children under the age of 18. If we learn we have collected or received personal data from a child under 18 years old without verification of parental consent, we will delete that information.
The Personal Data That We Collect or Process
“Personal data” is information that identifies, relates to, or describes, directly or indirectly, you as an individual, such as your name, email address, telephone number, home address, or payment information (for example, account information such as name, postal address, and email address). The types and categories of personal data we collect or process include account and contact information, including name, address, email address, phone number, and other contact information you provide us, device information, including your IP address and other device information.
We also collect statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. Additionally, we may collect technical information which includes information about your internet connection and usage details about your interactions with the Services, such as clickstream information to, through, and from our Services (including date and time), products that you view or search for; page response times, download errors, length of your visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from a page. If we combine or connect non-personal statistical or technical data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as personal information.
How We Collect Your Personal and Other Data
You Provide Information to Us
We collect information about you when you interact with our Services, such as any communications or submissions of any nature initiated by you through the Services.
Automatically Through Our Services
As you navigate through and interact with our Services, we may use automatic data collection technologies to collect information that may include personal data. Information collected automatically may include usage details, IP addresses, operating system, and browser type, and information collected through cookies.
Using automatic collection technologies helps us to improve our Services and to deliver a better and more personalized experience.
The technologies we use for this automatic data collection may include cookies, which is a small file placed on your device when you interact with the Services. You may refuse to accept or disable cookies by activating the appropriate setting on your browser or device. However, if you select this setting, you may be unable to access certain features of the Services. In addition, some parts of the Services may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those parts and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).
To the extent any of these automated technologies are considered a personal data sale, targeted advertising, or profiling, under applicable laws, depending on where you live, you may opt out from use of these automated technologies for such uses by contacting us a privacy@recirclesolutions.com. Please note that some Services features may be unavailable as a result.
When you interact with the Services, there are third parties that may use automatic collection technologies to collect information about your or your device. These third parties may include: advertisers, ad networks, and ad servers; analytics companies; your device manufacturer; and your internet or mobile service provider. These third parties may use tracking technologies to collect information about you when you use the Services. The information they collect may be associated with your personal data or they may collect information, including personal data, about your online activities over time and across different websites, apps, platforms, and other online services. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal data, to: provide you with the Services and any contents, features, information, or services that we make available through the Services; fulfill any other purpose for which you provide it; carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection; notify you when Services updates are available and about changes to any products or services we offer or provide though them; in any other way we may describe when you provide the information; and for any other purpose with your consent.
The usage information we collect, whether connected to your personal data or not, helps us improve our Services and deliver a better and more personalized experience by enabling us to: estimate our audience sizes and usage patterns; store information about your preferences, allowing us to customize the Services according to your individual needs and interests; and recognize you when you return to our Services.
Who We Disclose Your Information To
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We may also disclose personal data that we collect or you provide as described in this privacy policy: to our subsidiaries and affiliates; to contractors, service providers, and other third parties we use to support our organization and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them; to fulfill the purpose for which you provide it; for any other purpose disclosed by us when you provide the information; and with your consent. This does not include SMS data collected for text messaging purposes; we address how we handle that information separately in the SMS Messaging section below.
We may also disclose your personal data: to comply with any court order, law, or legal process, including to respond to any government or regulatory request; and if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our organization, our customers, or others. The categories of personal data we may disclose include: account and contact information; account information; location information; device information; content and information you elect to provide to us; and identity document information.
SMS Messaging
When you communicate with us via SMS, we may collect limited personal data, such as your phone number, the content of your message, and the date and time of your message. We collect this data to facilitate communication, provide support, deliver updates, or share relevant information about our services. We will not use your SMS data for any other purposes without your explicit written consent. SMS mobile phone numbers are not shared with third parties or affiliates for marketing purposes. Additionally, we do not sell, rent, or share your SMS data with third parties unless required by law.
To ensure you have control over your communication preferences, we operate on an opt-in basis for SMS notifications. We will only communicate through SMS in response to SMS communication initiated by you or upon your consent for us to use SMS communication with you. You have the right to stop receiving SMS notifications or communications at any time by replying with “STOP” to any of our messages to opt-out or by emailing us at privacy@recirclesolutions.com. If you change your mind, you can always opt back in by following the opt-in process. Standard message and data rates may apply to SMS messages sent and received. You are solely responsible for any fees or charges incurred from your mobile carrier related to SMS communication.
Messaging frequency may vary. You may expect to receive SMS messages from us only when necessary to respond to SMS messaging initiated by you. We do not engage in unsolicited marketing messages via SMS without your explicit consent.
Your State Privacy Rights
Depending on your state of residency, you may have certain rights related to your personal data, including:
Important: The exact scope of these rights vary by state. There are also several exceptions where we may not have an obligation to fulfill your request. To exercise any of these rights, please email privacy@recirclesolutions.com.
Some browsers and browser extensions support the Global Privacy Control (“GPC”) that can send a signal to process your request to opt out from certain types of data processing, including data “sales” as defined under certain laws. When we detect such a signal, we will make reasonable efforts to respect your choices indicated by a GPC setting as required by applicable law.
How We Protect Your Personal Data
We use commercially reasonable administrative, physical, and technical measures designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal data transmitted to, through, using, or in connection with the Services. In particular, email, texts, and chats sent to or from the Services may not be secure, and you should carefully decide what information you send to us via such communications channels. Any transmission of personal data is at your own risk. The safety and security of your information also depends on you. You are responsible for taking steps to protect your personal data against unauthorized use, disclosure, and access.
How We Retain Your Personal Data
We keep the categories of personal data described in this policy for as long as reasonably necessary to fulfill the purposes described or for as otherwise legally permitted or required, such as maintaining the Services, operating our organization, complying with our legal obligations, resolving disputes, and for safety, security, and fraud prevention. This means that we consider our legal and business obligations, potential risks of harm, and nature of the information when deciding how long to retain personal data. At the end of the retention period, personal data will be deleted, destroyed, or deidentified.
Changes to Our Privacy Policy
We may update this policy from time to time, and we will provide notice of any such changes to the policy as required by law. The date the privacy policy was last updated is identified at the top of the page. We will notify you of changes to this policy by updating the “last updated” date and posting the updated policy on the Services. We may email or otherwise communicate reminders about this policy, but you should check our Services periodically to see the current policy and any changes we have made to it.
Contact Information
To exercise your rights or ask questions or comment about this privacy policy or our privacy practices, contact us at: privacy@recirclesolutions.com or RE:CIRCLE Ontario, LLC, Attn: Privacy Counsel, 170 N. Turner Avenue, Ontario, California 91761.
