Effective Date: June 12, 2025

1. Introduction

White Circle Agency (“we,” “our,” or “us”) is committed to protecting your privacy. This policy explains how we collect, use, disclose, and safeguard your personal data in connection with our advertising and media-buying services (“Services”).

By using our Services or providing us with personal information, you consent to the terms of this Privacy Policy.

2. Data We Collect

2.1 Personal Data You Provide

• Identity & contact (e.g. name, business name, email, phone)

• Payment and billing information (e.g. credit card, invoice address)

• Authentication data (e.g. usernames, passwords)
  
  

2.2 Automatically Collected Data

• Usage info: IP address, device/browser metadata, timestamps, pages visited

• Analytics: Ads clicked, campaign performance data, engagement metrics
  
  

2.3 Third‑Party Partners/Data Sources

• Social platforms (e.g. Facebook, TikTok, Google Ads) supplying campaign data

• Analytics services (e.g. Google Analytics)

• Third‑party cookies, pixels, and tracking technologies
  
  

3. How We Use Your Data

We process personal data for the following purposes:

• Account management: registration, authentication, and support

• Delivering Services: creating, optimizing, and reporting your campaigns

• Billing & payments: invoicing, processing, and tracking payments

• Performance analytics: insights into campaign effectiveness and usage

• Legal compliance & safety: fraud prevention, legal obligations, dispute resolution

• Marketing: (with your consent) sending newsletters and updates
  
  

4. Legal Basis for Processing

If you’re in the EU, UK, or similar jurisdictions, we rely on:

• Contractual necessity (to provide services)

• Legitimate interests (e.g. service improvement, fraud detection)

• Consent (for marketing emails or data transfers)

• Legal obligation (e.g. compliance with financial regulations)
  
  

5. Sharing and Disclosure

We may share data with:

• Service providers (e.g. ad platforms, analytics, CRM, payment processors)

• Third‑party partners for campaign delivery and reporting

• Legal authorities if required by law or to protect rights

• Affiliates & successors in case of reorganization or acquisition (with notice)
  
  

6. International Data Transfers

We and our providers may transfer data across borders (e.g. US, EU).
When transferring from the EEA or UK, we rely on appropriate safeguards—such as Standard Contractual Clauses—or your consent.

7. Data Retention

• Account & billing data: retained for up to 7 years (for tax/legal reasons)

• Usage/campaign data: retained while your account exists, plus up to 3 years

• Support correspondence: kept for 2 years
  
  

8. Your Rights

Depending on your jurisdiction, you may have:

• Access to your personal data

• Correction or update of your data

• Deletion or restriction of processing

• Portability (data exports)

• Objection to processing (e.g. marketing or profiling)

• To withdraw consent at any time

To exercise your rights, please contact us at privacy@whitecircleagency.com. We’ll respond within applicable legal timelines.

9. Cookies & Tracking Technologies

We use cookies and similar tools for:

• Platform functionality and user sessions

• Analytics and performance optimization

• Targeted advertising and retargeting

You can manage cookie preferences through our cookie banner and browser settings.

10. Security

We implement industry-standard safeguards such as encryption, firewalls, access controls, and regular security reviews. However, no system is 100% secure—use at your own risk.

11. Children’s Privacy

Our Services are not directed to children under 16. We do not knowingly collect data from children. If you believe we have, please contact us to have it removed.

12. Changes to This Policy

We may update this Privacy Policy. We’ll notify you by email or through the Platform, and update the “Effective Date.” Continued use after changes implies acceptance.