Privacy policy

Effective Date: August 14, 2026

College Circle LLC (“College Circle,” “we,” “us,” or “our”) respects your privacy and is committed to protecting the personal information you provide to us. This Privacy Policy describes how we collect, use, disclose, and protect information in connection with our website located at www.mycollegecircle.com (the “Website”) and the services made available through the Website, including Memberships in College Circle’s student concierge programs (collectively, the “Services”).

This Privacy Policy applies to information collected through the Website and in connection with your use of the Services. It does not apply to information collected through third-party websites, applications, or services that we do not control.

By accessing or using the Website or Services, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with this Privacy Policy, please do not use the Website or Services.

1. INFORMATION WE COLLECT

A. Information You Provide to Us

We may collect personal information that you voluntarily provide when you interact with us or sign up for or use our Services. Depending on how you interact with us, this information may include:

• Name;
• Email address;
• Mailing address;
• Telephone number;
• Billing and payment information;
• Information you provide when communicating with us;
• Information you provide in connection with your Membership and use of our Services; and
• Any other information you voluntarily choose to provide.

We collect only the information reasonably necessary for providing the Services, the purposes described in this Privacy Policy, or as otherwise disclosed to you at the time of collection.

B. Information Collected Automatically

When you visit the Website, we may automatically collect certain technical and usage information, such as:

• Internet Protocol (“IP”) address;
• Browser type and version;
• Device type;
• Operating system;
• Referring and exit pages;
• Pages viewed and links clicked;
• Date and time of Website visits;
• General geographic information derived from your IP address;
• Information concerning how you interact with the Website; and
• Other technical information made available to us by your browser or device.

This information generally does not directly identify you, but it may be associated with information that does.

C. Cookies and Similar Technologies

We may use cookies, web beacons, pixels, tags, and similar technologies to operate and improve the Website, understand how visitors use the Website, maintain user sessions, remember preferences, and perform analytics.

Cookies are small data files stored on your device. You may be able to control or disable cookies through your browser settings. If you disable cookies, certain portions of the Website may not function properly.

If we use third-party analytics or advertising technologies that place cookies or similar technologies on the Website, those third parties may collect information about your use of the Website subject to their own privacy policies.

2. HOW WE USE PERSONAL INFORMATION

We may use personal information for the following purposes:

• To provide, operate, maintain, and improve the Services;
• To create and administer user memberships;
• To process transactions and payments;
• To communicate with you regarding your membership or use of the Services;
• To respond to inquiries, requests, and customer-service communications;
• To send transactional, administrative, security, and service-related communications;
• To send marketing communications where permitted by law and consistent with your preferences;
• To personalize and improve your experience;
• To monitor and analyze Website usage and trends;
• To detect, prevent, and address fraud, abuse, security incidents, and other harmful or unlawful activity;
• To enforce our agreements and policies;
• To comply with applicable laws, regulations, legal processes, or governmental requests; and
• For other purposes disclosed to you at the time we collect the information or with your consent.

We may also use information in aggregated, de-identified, or anonymized form for lawful business purposes. To the extent permitted by applicable law, we will not attempt to re-identify information that we have de-identified.

3. HOW WE DISCLOSE PERSONAL INFORMATION

We do not sell your personal information in the ordinary course of operating our business.

We may disclose personal information in the following circumstances:

A. Service Providers

We may share personal information with third-party vendors, contractors, consultants, and service providers that perform services on our behalf, such as:

• Membership services;
• Website hosting;
• Cloud storage;
• Payment processing;
• Email delivery;
• Customer support;
• Analytics;
• Information technology and security;
• Fraud prevention; and
• Other business and operational services.

These parties may access personal information only as reasonably necessary to perform services for us and subject to appropriate contractual or other protections.

B. Legal and Safety Purposes

We may disclose information when we reasonably believe disclosure is necessary to:

• Address emergency situations where reasonably necessary to protect health and safety;
• Comply with applicable law, regulation, legal process, subpoena, or governmental request;
• Protect our rights, property, or safety;
• Protect the rights, property, or safety of our users or others;
• Investigate fraud, security incidents, or other unlawful activity; or
• Enforce our agreements or policies.

C. Business Transfers

If College Circle is involved in a merger, acquisition, financing, reorganization, sale of assets, bankruptcy, dissolution, or similar transaction, personal information may be transferred as part of that transaction, subject to applicable law.

D. With Your Consent

We may disclose personal information for other purposes with your consent or at your direction. More information regarding disclosure of Member information is set forth in the Membership Agreement.

4. PAYMENT INFORMATION

If you purchase a Membership through the Website, payments may be processed by third-party payment processors. We may not directly receive or store certain payment card information, such as complete credit or debit card numbers.

Payment information is handled in accordance with the applicable payment processor's privacy policy and security practices.

5. MARKETING COMMUNICATIONS

We may send you promotional emails or other marketing communications about our Services, products, or other offerings where permitted by applicable law.

You may opt out of receiving promotional emails by using the unsubscribe mechanism included in those communications. Even if you opt out of promotional communications, we may continue to send you transactional or administrative communications that are necessary to provide the Services or administer your account.

6. DATA RETENTION

We retain personal information for as long as reasonably necessary to fulfill the purposes for which it was collected, including providing the Services, maintaining business and transaction records, complying with legal obligations, resolving disputes, enforcing agreements, and protecting our legal rights.

The specific retention period may vary depending on the type of information and the purpose for which it was collected.

When personal information is no longer reasonably necessary for these purposes, we may delete it, anonymize it, or securely dispose of it, subject to applicable legal and business requirements.

7. DATA SECURITY

We use reasonable administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, disclosure, alteration, and destruction.

However, no method of transmitting or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of your personal information.

8. YOUR PRIVACY RIGHTS

Depending on where you live and subject to applicable law, you may have certain rights regarding your personal information.

These rights may include the right to:

• Request access to personal information we maintain about you;
• Request correction of inaccurate personal information;
• Request deletion of personal information;
• Request information about how we collect, use, and disclose personal information;
• Opt out of certain sales or sharing of personal information, where applicable;
• Opt out of certain targeted or interest-based advertising, where applicable;
• Request portability of certain personal information; and
• Appeal a decision concerning a privacy-rights request, where applicable.

The availability and scope of these rights depend on applicable law and may vary based on your state of residence and circumstances.

To exercise applicable privacy rights, please contact us using the information provided in the Contact Us section below.

We may need to verify your identity before completing certain requests. We will use personal information provided in connection with a privacy request solely for purposes reasonably related to processing and responding to the request, subject to applicable law.

You may also designate an authorized agent to submit certain requests on your behalf where permitted by applicable law. We may require appropriate documentation confirming the agent's authority.

We will not unlawfully discriminate against you for exercising privacy rights available to you under applicable law.

9. STATE-SPECIFIC PRIVACY RIGHTS

Certain states provide residents with additional privacy rights. These rights may apply only if specified statutory thresholds or other requirements are satisfied.

Where applicable, residents may have rights concerning the collection, use, disclosure, sale, or sharing of personal information, including rights to access, correct, delete, obtain a copy of, or limit certain uses of personal information.

If you are a resident of a state that provides specific privacy rights, you may exercise those rights by contacting us as described below. We will process your request in accordance with applicable law.

If applicable law provides you with a right to appeal our decision regarding a privacy request, you may submit an appeal by contacting us at privacy@mycollegecircle.com.

10. DO NOT TRACK

Some web browsers have a “Do Not Track” feature that sends a signal to websites indicating that you do not wish to be tracked.

Because there is currently no universally accepted standard for responding to browser-based Do Not Track signals, our Website may not respond to such signals unless required by applicable law.

11. THIRD-PARTY WEBSITES AND SERVICES

The Website may contain links to websites, applications, or services operated by third parties.

We are not responsible for the privacy practices, security, or content of third-party websites or services. Your interactions with third-party websites and services are governed by their own privacy policies and terms.

We encourage you to review the privacy policies of third parties before providing them with personal information.

12. CHILDREN'S PRIVACY

The Website and Services are not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13.

If you believe that a child under 13 has provided personal information to us, please contact us at the address below. If we become aware that we have collected personal information from a child under 13 without appropriate authorization, we will take reasonable steps to delete the information.

If applicable law establishes a different minimum age for consent to processing of personal information, we will comply with the requirements of that law.

13. INTERNATIONAL USERS

The Website and Services are operated from the United States. If you access the Website from outside the United States, your information may be transferred to, stored in, or processed in the United States or other jurisdictions where we or our service providers operate.

Privacy and data-protection laws in those jurisdictions may differ from those in your jurisdiction.

14. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our business practices, technology, legal requirements, or Services.

When we make changes, we will update the “Effective Date” at the top of this Privacy Policy. If we make material changes, we may provide additional notice as required by applicable law.

Your continued use of the Website or Services after the effective date of an updated Privacy Policy constitutes your acknowledgment of the updated Privacy Policy, to the extent permitted by law.

15. CONTACT US

If you have questions about this Privacy Policy or wish to exercise a privacy right, please contact us:

College Circle LLC
1360 Walnut St. Apt 401, Boulder CO 80302
privacy@mycollegecircle.com

16. ADDITIONAL INFORMATION

This Privacy Policy is intended to describe our general privacy practices. Certain Services or portions of the Website may have additional privacy notices that provide more specific information regarding the collection or use of personal information.

Where an additional notice conflicts with this Privacy Policy with respect to a particular Service or processing activity, the more specific notice will control for that activity to the extent required by applicable law.

‍