Privacy Policy
Effective date: August 1, 2026 | Circle of Influence ("Company," "We," "Us," "Our")
This Privacy Policy describes how Circle of Influence ("Company," "We," "Us," "Our") collects, uses, and discloses Your information when You use our content publishing automation platform (the "Service"), and explains Your privacy rights and how the law protects You.
By using the Service, You agree to the collection and use of information in accordance with this Privacy Policy.
1. Interpretation and Definitions
Interpretation
Words whose initial letters are capitalized have meanings defined under the following conditions. These definitions apply whether the terms appear in singular or plural form.
Definitions
For the purposes of this Privacy Policy:
Account means a unique account created for You to access the Service.
Affiliate means an entity that controls, is controlled by, or is under common control with a party, where "control" means ownership of 50% or more of the shares, equity interest, or other securities entitled to vote for election of directors or other managing authority.
Application refers to Circle of Influence, the software platform provided by the Company.
Company refers to Circle of Influence.
Country refers to Wyoming, United States.
Connected Account means a third-party social media account (such as Instagram) that You link to the Service.
Device means any device that can access the Service, such as a computer, cell phone, or tablet.
Personal Data (or "Personal Information") is any information that relates to an identified or identifiable individual. We use "Personal Data" and "Personal Information" interchangeably unless a specific law requires otherwise.
Service refers to the Application.
Service Provider means any person or company that processes data on behalf of the Company, including to facilitate the Service, provide services related to the Service, or help analyze how the Service is used.
Usage Data refers to data collected automatically, either generated by use of the Service or from the Service's infrastructure itself.
You means the individual accessing or using the Service, or the company or legal entity on whose behalf such individual is accessing or using the Service.
2. Types of Data We Collect
Personal Data
While using the Service, We may ask You to provide certain personally identifiable information that can be used to contact or identify You, including:
Email address
First name and last name
Payment Data
To subscribe to paid tiers of the Service, You will need to provide payment information (such as credit card or bank account details). Payment processing is handled by our third-party payment processor, Stripe, and We do not directly store full payment card numbers on Our own systems. We retain limited billing records — such as invoice history, transaction amounts, and dates — for accounting, tax, and fraud-prevention purposes.
Instagram and Other Connected Account Data
The Service allows You to connect Your Instagram professional account(s) in order to schedule and publish content. When You connect an Instagram account, We collect and store:
an access token issued by Instagram, which authorizes the Service to publish content on Your behalf;
Your Instagram user ID;
Your Instagram username and account type;
The identifier of each post the Service publishes to Your account, and the date and time it was published.
We never receive or store Your Instagram password. Access is granted by You through Instagram's own login and consent screen, and is limited to the instagram_business_basic and instagram_business_content_publish permissions. We request no other Instagram permissions.
Accordingly, We do not access or store Your existing posts, Your comments or the comments of others, Your direct messages, Your follower or audience information, or Your engagement, insights, or analytics metrics.
This data is accessed via Instagram's API and is subject to Meta's Platform Terms and Developer Policies in addition to this Privacy Policy.
You may disconnect a connected Instagram account at any time using the Disconnect option in the Service, which deletes the stored access token and revokes Our ongoing access to it. See Section 6 for all available routes.
Usage Data
Usage Data is collected automatically when using the Service. This may include Your Device's IP address, browser type and version, the pages of the Service You visit, the time and date of Your visit, time spent on those pages, unique device identifiers, and other diagnostic data.
When You access the Service through a mobile device, We may also collect the type of mobile device You use, Your mobile device's unique ID, mobile operating system, the type of mobile browser You use, and other diagnostic data.
3. Use of Your Personal Data
The Company may use Personal Data for the following purposes:
To provide and maintain the Service, including monitoring its usage;
To manage Your Account and Your registration as a user of the Service;
To confirm which Instagram account content will be published to, and to display that account back to You — using Your Instagram user ID and username;
To publish the content You or Your authorized users have approved, at the times You schedule — using the access token You granted;
For the performance of a contract: the development, compliance, and undertaking of the subscription contract for the Service;
To contact You by email or other electronic means regarding updates, security notices, or informative communications related to the Service;
To provide You with news, offers, and information about goods and services similar to those You've already used, unless You have opted out;
To manage and respond to Your requests to Us;
For business transfers: to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets;
For other purposes, such as data analysis, identifying usage trends, and improving the Service.
Limits on Our use of Instagram data. Notwithstanding the purposes listed above, We do not use data obtained through Instagram's API for advertising or ad targeting, for building profiles about You, for training machine learning or artificial intelligence models, or for any purpose other than providing the scheduling and publishing features You have requested. We do not sell, rent, or license data obtained through Instagram's API. The purposes described above relating to news and offers, business partners, and data analysis or usage trends do not apply to data obtained through Instagram's API.
We may share Your Personal Data in the following situations:
With Service Providers: including our payment processor (Stripe) and infrastructure or analytics providers, to operate and improve the Service;
With Meta/Instagram: as necessary to publish or schedule content via Instagram's API on Your behalf, and as governed by Meta's own privacy and platform policies;
For business transfers: in connection with a merger, asset sale, financing, or acquisition;
With Affiliates: who will be required to honor this Privacy Policy;
With business partners: to offer You certain products, services, or promotions. This does not apply to data obtained through Instagram's API;
With Your consent: for any other purpose You have agreed to.
4. Retention of Your Personal Data
The Company retains Your Personal Data only as long as necessary for the purposes set out in this Privacy Policy, or as required to comply with legal obligations, resolve disputes, and enforce our agreements. Where possible, We apply shorter retention periods and reduce identifiability by deleting, aggregating, or anonymizing data. Unless otherwise stated, the periods below are maximums, and We may delete or anonymize data sooner:
User Accounts: retained for the duration of Your account relationship, plus up to 24 months after account closure.
Customer support data (tickets, correspondence, chat transcripts): up to 24 months from ticket closure.
Usage Data (application statistics, server logs, IP addresses): up to 24 months for security and improvement purposes.
Instagram access tokens: retained only while the Connected Account remains connected. Deleted immediately when You disconnect the account in the Service, and within 30 days of account deletion or a deletion request.
Other connected Instagram account data: retained only while the account remains connected, and deleted from Our systems within the timeframes described in our User Data Deletion Policy once disconnected or upon account deletion.
Billing records (invoice history, transaction amounts, and dates): retained for up to 7 years to comply with financial recordkeeping and tax obligations, as described in our User Data Deletion Policy.
We may retain data beyond these periods where required by law, necessary to establish or defend legal claims, at Your explicit request, or due to technical limitations such as encrypted backup schedules. When retention periods expire, We delete or anonymize Personal Data; residual copies may briefly remain in encrypted backups consistent with our backup rotation and are not restored except for security, disaster recovery, or legal compliance purposes.
5. Transfer of Your Personal Data
Your information, including Personal Data, is processed at the Company's operating locations and any other places where parties involved in processing are located, which may be outside Your state, province, country, or governmental jurisdiction. Where required by law, We ensure appropriate safeguards are applied to such transfers, and We take reasonable steps to ensure Your data is treated securely and in accordance with this Privacy Policy.
6. Delete Your Personal Data
You have the right to delete, or request that We assist in deleting, the Personal Data We have collected about You, including data associated with Connected Instagram accounts.
To disconnect a Connected Instagram account and delete its access token, You may use any of the following routes:
Disconnect in the Service. Selecting Disconnect deletes the stored access token immediately and ends Our ability to publish to that account.
Revoke access in Instagram. In the Instagram app, go to Settings → Apps and Websites → Active, and remove Circle of Influence. This revokes the token from Meta's side.
Contact Us at hello@circleofinfluence.io. We action deletion requests within 30 days and confirm by reply.
To delete other Personal Data, including Your Account, You may contact Us at the address above, or use the deletion options available in the Service.
Full details of our deletion process and timelines are set out in our User Data Deletion Policy, available at https://circleofinfluence.io/user-data-deletion. Please note We may need to retain certain information where We have a legal obligation or lawful basis to do so.
7. Disclosure of Your Personal Data
Business Transactions
If the Company is involved in a merger, acquisition, or asset sale, Your Personal Data may be transferred. We will provide notice before Your Personal Data becomes subject to a different Privacy Policy.
Law Enforcement
Under certain circumstances, the Company may be required to disclose Your Personal Data if required to do so by law or in response to valid requests by public authorities.
Other Legal Requirements
The Company may disclose Your Personal Data in the good-faith belief that such action is necessary to comply with a legal obligation, protect and defend the rights or property of the Company, prevent or investigate wrongdoing in connection with the Service, protect the personal safety of Users or the public, or protect against legal liability.
8. Security of Your Personal Data
The security of Your Personal Data is important to Us, but no method of transmission over the Internet or method of electronic storage is 100% secure. While We strive to use commercially reasonable means to protect Your Personal Data, We cannot guarantee its absolute security.
Instagram access tokens are stored in access-controlled systems available only to personnel who require them to operate the Service, and are transmitted only to Instagram's API. They are never displayed in the Service or included in email notifications.
9. Children's Privacy
Our Service does not address anyone under the age of 16. We do not knowingly collect personally identifiable information from anyone under 16. If You are a parent or guardian and are aware Your child has provided Us with Personal Data, please contact Us. If We become aware We have collected Personal Data from anyone under 16 without verification of parental consent, We take steps to remove that information from Our servers.
10. Your State Privacy Rights (U.S.)
Depending on Your state of residence, You may have additional statutory rights regarding Your personal data, including the right to know what data We hold about You, the right to correct inaccurate data, and the right to delete Your data — separate from and in addition to the process described in our User Data Deletion Policy. These rights currently exist, in varying forms, under laws including the California Consumer Privacy Act (CCPA/CPRA) and similar comprehensive privacy laws in states such as Virginia, Colorado, Connecticut, Texas, and others as they take effect. We do not sell or share Your personal data for cross-context behavioral advertising. To exercise any state-specific privacy right, contact Us at hello@circleofinfluence.io.
11. Links to Other Websites
Our Service may contain links to other websites not operated by Us, including Instagram and other third-party platforms. If You click a third-party link, You will be directed to that party's site. We advise You to review the Privacy Policy of every site You visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
12. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify You of changes by posting the new Privacy Policy on this page, updating the "Effective date" above, and, for material changes, notifying You by email or a prominent notice on the Service prior to the change becoming effective. You are advised to review this Privacy Policy periodically.
13. Contact Us
If You have any questions about this Privacy Policy, You can contact Us at: hello@circleofinfluence.io