Effective on July 1, 2021
Scope of this Policy
The Information We Collect
You don’t have to create an account to use some of our service features, such as searching and viewing public Expat. If you do not create an account, we do collect information about your browser and device (IP address, browser version, etc.) but we cannot link that information to an identifiable person unless and until you create an account.
If you do choose to create an account, you must provide us with some personal information so that we can provide the Service. This includes information you provide to us, such as:
registration information when you Sign Up;
- profile information, such as city and country, language, and availability;
- uploaded content (image, notes, etc.);
- session recordings (if you have consented to recording of session)
- questions, comments, or other information when you communicate with us, by phone, email, or via third party social media sites, or participate in interactive features of the Service (including Customer Support messages and online tool chat messages);
Customers and parents
We may also collect personal information related to your documentation of and payment for sessions; questions related to living abroad; Expat feedback of an customer (once the parent provides consent for submission); and content you upload for the purposes of transmitting it to another user or for public display on the Site or Apps.
We may also collect your Social Security number (SSN) or Federal Employer Identification Number (FEIN) date of birth and address, for tax purposes or to complete a background check; we also collect content you upload for purposes related to transmission to other users or public display on the Site or Apps. We also collect bank account information to facilitate payment.
If you elect to pay for a session with a credit card, we will collect your name, credit card number, expiration date, and address information associated with the account. All financial information, other than credit card numbers, is stored and encrypted in our System in full compliance with the Payment Card Industry Data Security Standard. We do not store credit card numbers. We collect bank information from Expats who list their services on the platform for the purposes of transmitting payment to them.
If you are an Expat and elect to pay for a background check, we will collect credit card information to order a background check on your behalf. Payment information entered into our System solely to procure a background check will not be stored on our servers.
Additional Information We Receive About You
Information we collect automatically
We also gather additional personal information when you use the Service, including type of browser you use, access time, pages viewed, IP address, and, if enabled, geolocation; and we collect information about the computer or mobile device you use to access the Service, including without limitation operating system and unique device identifiers and mobile network information. This data is used to better understand and enhance Users experience with the Service and on the Site and Apps. Expat Circle may publish aggregate User statistics or share them with third parties.
Information we collect from other sources
We may also obtain personal information from our background check administrator and combine that with information we collect through the Service. For example, we may view information about you for the purposes of identity verification, credit bureaus, and other background check information, including from publicly available sources, but this information is not stored on our systems. If you log into your account through single sign-on services, like Facebook Connect, you provide Expat Circle with permission to access certain information about you, such as your Facebook User ID, user profile, and profile picture. User generated content on the Site or App that is cross-posted through certain social networking preferences (e.g. pages you “Like” or “Follow”) may be viewed by the general public. Accordingly, Expat Circle cannot ensure the privacy of any personal information included in such User generated content.
How We Use Your Information
Expat Circle may use your personal information for various purposes, including:
- account creation and to provide the Service, including without limitation, access to previous sessions, Expat-matching services, information about prospective Expats, and facilitating communication directly between customers and Expats;
- to process transactions and billing;
- for identification and authentication purposes;
- to communicate with you concerning the Service, User requests, transactions, security, privacy and administrative issues relating to your use of the Service, and services that we think may be of interest to you;
- process and deliver contest and sweepstakes entries and rewards and verify eligibility;
- personalize and improve the Service and deliver and display targeted advertisements on our Service, content or features in the Service and on other sites or apps; and
- for administration of and troubleshooting regarding the System.
Information We Share And Disclose
We do not sell your personal information. To make the Site work, we may need to share some of your personal information with other Users, our affiliates, third parties, and service providers. This section explains when and why we share your information.
Your member profile and information that you post or share, such as Expat bio, educational background, city and state, rate, photos, reviews, comments, suggestions, and information about you or your experience, may be seen and shared with other Users of our Service. You should therefore think carefully before deciding what information you share.
Information Shared Between Users
Expat Circle shares a minimum amount of personal information between Expats and customers in order to facilitate the arrangement of sessions, including, your first name and last initial, city, photo, and details about the services you seek or provide. Messages to customers also, contain Expats’ usernames, which include the Expat’s first and last name. In the case of Expat feedback of a customer, we will transmit it as you ask us to.
If you choose to use our referral service, to tell a friend about our Service, we will ask you for your friend’s email address. We will automatically send your friend an email inviting him or her to visit the Site and up to two reminders. Expat Circle stores this information for the sole purpose of sending this one-time email and reminders and tracking the success of our referral program. Your friend may click Unsubscribe at the bottom of any email, or contact us at email@example.com to request removal from our database.
Cookies and Similar Technologies
Affiliates and Change of Ownership
Law and Public Interest
Managing Your Personal Information With Us
Modifying or correcting your information
If you have an account with us, you can access, correct, delete, or modify some of the personal information you provided to us in your account settings.
Expat Circle may send you email communications periodically detailing new Service features or promotions. You may unsubscribe from these messages by using the link at the bottom of the email. We will still send you email messages about the status of your account or any notices as required by law. You may not opt-out of receiving these administrative emails so long as you continue to use the Service. If you wish to terminate your account, please contact us.
You can prevent your device from sharing location information through your device’s system settings. But if you do, this may impact Expat Circle’s ability to provide you our full range of features and services.
You can modify your cookie settings on your browser settings. If you delete or choose not to accept our cookies, you may be missing out on certain features of the Service.
Do Not Track
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not want them to track your online activities. The Service does not currently support Do Not Track requests at this time.
The California Consumer Privacy Act provides some California residents with the additional rights listed below.
Right to Know
You have the right to know and see what data we have collected about you over the past 12 months and the speciﬁc pieces of personal information we have collected about you.
Right to Delete
You have the right to request that we delete the personal information we have collected from you (and direct our service providers to do the same). Note that deletion requests are subject to certain limitations, for example, we may keep information as required or permitted by law, to process transactions, certain account-related information, to facilitate User requests, and protect and fix our system.
You have the right not to be discriminated against for exercising any of the rights listed above.
Exercising Your California Privacy Rights
To request access to or deletion of your personal information, or to exercise any other data rights under California law, please write us at firstname.lastname@example.org. Please include your full name, email address, and phone number associated with your use of the Site, along with why you are writing, so that we can process your request in an efﬁcient manner.
We aim to respond to a consumer request for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension period in writing.
Children and Our Services
This Service is not intended for use by children under 13 years of age.
Expat Circle does not knowingly collect personally identifiable information from children under the age of 13. If you are under the age of 13, please do not provide your contact information or any other personally identifiable information to Expat Circle. If you are the parent or legal guardian of someone under the age of 13 who may have provided us with information without your knowledge or consent, please contact us to have this information removed. All contact, including sessions, between an Expat and any minor should, of course, take place only in a supervised setting.
How to Contact Us