Privacy Policy

Last updated: October 1, 2026

1. Introduction

Remora Group LLC ("we", "us", "our") operates CirclesCheck. This Privacy Policy explains how we collect, use, and protect information when you use our Service.

2. Information We Collect

We collect:

  • Account information: Name, email address, organization name, and password (hashed)
  • Screening data: Names, dates of birth, nationalities, and other data you submit for screening
  • KYC data: Identity document images and extracted data submitted for verification
  • Usage data: API call logs, screening counts, and feature usage
  • Optional website activity: A random browser identifier, page paths, campaign sources, return visits, and selected website actions when you accept analytics
  • Sales inquiries and preferences: Contact details and requirements you provide, your requested follow-up, and your separate marketing-email choice
  • Payment data: Processed by Stripe; we do not store full card numbers

3. How We Use Your Information

  • To provide and operate the screening and KYC verification services
  • To manage your account and process payments
  • To communicate with you about your account and the Service
  • To monitor usage for billing and rate limiting
  • To improve and maintain the Service
  • To respond to your requests and understand the needs of known accounts using account activity counts; customer screening details and identity documents are excluded from the sales view
  • To send product updates and offers if you opt in; signing up does not opt you into marketing emails

4. Data Retention

Screening results are retained for the duration of your account for audit trail purposes. KYC document images are retained for 90 days after verification, then permanently deleted. Account data is retained until you delete your account or request deletion. Optional anonymous website activity is kept for 30 days, and activity linked with your separate permission is kept for 90 days. Withdrawal removes the current browser journey and its associations; independently submitted requests and account records follow their own retention rules.

5. Data Sharing

We do not sell your data. We share data only with:

  • Stripe: For payment processing
  • Infrastructure providers: For hosting and operating the Service
  • Law enforcement: When required by law or valid legal process

6. Security

We use industry-standard measures to protect your data, including encrypted connections (TLS), hashed passwords, hashed API keys, and access controls. However, no system is completely secure, and we cannot guarantee absolute security.

7. Your Rights

You have the right to:

  • Access the personal data we hold about you
  • Request correction of inaccurate data
  • Request deletion of your data
  • Export your screening history
  • Change your marketing-email preference in Settings and your optional tracking choice below

To exercise these rights, contact us at privacy@circlescheck.com.

8. Cookies

Essential cookies support authentication and remember your privacy choices. Optional browser analytics, a random first-party browser cookie, and campaign-attribution storage run only after you accept analytics. The website records allowed page paths and selected actions without query strings, form input, screen recordings, or customer screening data. These choices are shared between the CirclesCheck website and app and can be changed at any time. Account activity required to operate the service, apply allowances, and maintain records is recorded separately from optional browser analytics.

A separate optional choice lets us connect earlier and future marketing-website visits to details you submit or an account you sign into. Contact details remain in our private prospect system and are not sent to Umami. Browser activity is an association, not proof that one person viewed every page. Choosing analytics alone does not enable contact linking. Third-party company-identification tools are disabled unless separately configured and accepted. Tracking choices are separate from your preference for marketing emails.

9. Changes

We may update this policy from time to time. We will notify you of material changes via email. Continued use after changes constitutes acceptance.

10. Contact

Questions about this policy? Contact us at privacy@circlescheck.com.