Effective as of March 1, 2023

This Privacy Policy explains how Innercircle (“Innercircle”, “we”, and “us”) collects, uses, and discloses information, and any other websites that link to this Privacy Policy (each a, “Website”), our platform, and any other applications or services operated by Innercircle that link to this Privacy Policy (collectively with each Website, the “Services”). This Privacy Policy is incorporated by reference into Innercircle’s Terms of Use (the “Terms”). By using the Services you consent to the processing of your information as set forth in this Privacy Policy.


Information We Collect When You Visit Our Website or Platform
We collect any information that you provide us when you visit our Website. On our Website you may provide us with your contact information, including your name, email and phone number, to learn more about our offerings. We may also collect information through your communications with our customer-support team. We automatically collect certain technical information from your computer or mobile device when you visit our Website. We may collect information using cookies or similar technologies. Cookies are pieces of information that are stored by your browser on the hard drive or memory of your computer or other Internet access device. These tools allow us to passively collect information about your computer and/or device, including your IP address, web browser type, mobile operating system version (to the extent applicable), and unique device identifiers. We may also collect and store your browser settings and preferences. When our customers visit our platform, we collect IP address, an identifier indicating which advertising campaign is running, and information about your interactions with the platform.

We use website and application analytics services provided by third parties that use cookies and other similar technologies to collect information about Website use and to report trends, without identifying individual visitors. The third parties that provide us with these services may also collect information about your use of third-party websites. You can learn about Google’s practices in connection with this information collection and how to opt out of it by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.


Service-Related Usage
We use the information we collect for a number of purposes, including: providing, supporting, and improving the Services, and developing new products and services. We may also use the information to understand and analyze the usage trends and preferences of consumers.

Communications to Our Customers and Website Visitors
We use your information to communicate with you. For example, we may send email messages to the email address you provide to us to for informational and operational purposes, such as account management and customer service.

Marketing to Our Customers and Website Visitors
We may use your information for marketing purposes, such as providing you with promotional materials that may be useful, relevant, valuable or otherwise of interest. Where required under applicable law, we will obtain your prior opt-in consent to send you electronic marketing communications. You can opt-out of receiving further promotional messages from us by following the unsubscribe instructions provided in the promotional email you receive.

Compliance with Applicable Law and Our Own Obligations
We may also process the information we collect about you or from you for the following purposes: (i) to enforce our Terms or other legal rights, including intellectual property infringement; (ii) as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and (iii) comply with industry standards and our policies.

Aggregate Data
We may de-identify your information and process it in an anonymous and aggregated form for other purposes than described above.


Service Providers
We work with third party service providers who provide website development, hosting, maintenance, and support as well as other business services for us. To the extent it is necessary for these service providers to provide the Services, these third parties may have access to or process your information.

As Required by Law and Similar Disclosures
We may disclose information about you: (i) if we are required to do so by law, regulation, or legal process, such as a court order or subpoena; (ii) in response to requests by government agencies, such as law enforcement authorities; (iii) when we believe disclosure is necessary or appropriate to protect against or respond to physical, financial or other harm, injury, or loss to property; or (iv) in connection with an investigation of suspected or actual unlawful activity.

Merger, Sale, or Other Asset Transfers
We reserve the right to transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.

We may also disclose your information with your permission. In addition, we may share anonymous and aggregated reports and information on user demographics and traffic patterns with third parties.


Browser Settings
If you do not want us to collect information through the use of cookies, your browser may allow you to be notified when you receive certain types of cookies and restrict or block certain cookies. Each browser is different, so you should check your browser’s “Help” menu to learn how to change your cookie preferences. Please be aware that if you block or reject cookies, some online services may not work properly. In addition, if you elect to use a new or different browser, you will need to apply the appropriate opt out to that browser.

Do Not Track Signals
We do not currently respond to web browser “do not track” signals or other mechanisms that provide a method to opt out of the collection of information across the networks of websites and online services in which we participate. If we do so in the future, we will describe how we do so in this Privacy Policy.

We maintain administrative, technical, and physical safeguards designed to protect the information you provide or we collect against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. Moreover, we are not responsible for the security of information you transmit to the Services over networks that we do not control, including the Internet and wireless networks.

We do not knowingly collect personal information online from children under the age of 13. If Innercircle becomes aware that any person submitting information to the Services is under the age of 13, we will promptly take steps to delete any personal information. If you become aware that your child or any child under your care has provided us with personal information without your consent, please contact us at the contact information listed below.

We are based in the U.S. and the information We and Our Service Providers collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored, and used in the U.S. Data protection laws in the U.S. may be different from those of your country of residence. Your use of the Service or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of your information, including Personally Identifiable Information, in the U.S. as set forth in this Privacy Policy.

If you are visiting from the United States, there are additional privacy protections, including: a) the right to see what data we have about you, your computer or device (i.e., the right to know), b) the right to delete the data we have about you, your computer or device (i.e., the right to delete) and c) the right to opt-out of the sale of data about you, your computer or device to certain third parties (i.e., the right to opt-out from sales of your information). We do not discriminate against you if you exercise any of the above rights. Moreover, we may not be able to honor a right if doing so would violate applicable law.

You are entitled to see and delete the personal information that we have about you. To do so, please contact us.


This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our information practices or relevant laws. To inform you of any change, we will post the updated Privacy Policy on the Websites and indicate at the top of the Privacy Policy when it was updated. If we decide to use particular personal information in a manner materially different from that stated at the time it was collected, we will let you know through our Services, by email, or other communication.


If you have any questions or comments about this Privacy Policy, our privacy practices or if you would like to exercise your rights and choices, please contact us here: privacy@myinnercircle.ai