Privacy Policy
Draft, not yet in force. This document has not been reviewed by counsel and every [BRACKETED TOKEN] below still needs a real value.
This policy explains what [LEGAL ENTITY NAME] ("CircaSale", "we", "us") collects when you use circasale.com and the CircaSale applications, why we collect it, who we share it with, and what you can ask us to do about it.
1. Who this applies to, and where
CircaSale is offered only in the United States. The Service is intended for organizations and individuals located in the United States. It is not directed to, marketed to, or intended for individuals in the European Economic Area, the United Kingdom, or Switzerland, and we do not knowingly collect their personal information or monitor their behavior. If you are outside the United States, please do not use the Service.
All personal information handled through the Service is stored and processed in the United States.
Two kinds of people, two different roles
It matters which one you are:
- Organizers: the people and organizations who sign up for a CircaSale account. For your information, we are the controller: we decide why and how it is used, and this policy governs it directly.
- Consignors, volunteers, and shoppers: the people whose information an organizer enters or captures while running a sale. For that information, the organizer is the controller and we are their service provider. We handle it on their instructions. If you are a consignor or a shopper, the organizer running your sale is the right first contact, and their own privacy notice governs. We will help them respond to you.
2. What we collect
| Category | Examples | Where it comes from |
|---|---|---|
| Organizer account | Name, work email, password (hashed), organization name, role, postal address, contact phone | You, at signup and in settings |
| Agreement records | Which version of our Terms you accepted, the wording shown, timestamp, IP address, browser user-agent | Recorded automatically at signup |
| Billing | Event fees charged, payment status, Stripe customer and payment identifiers, billing country | You and Stripe. We never see or store your full card number. |
| Sale data | Events, inventory items, consignor and volunteer records, transactions, payouts | Entered by the organizer, their consignors, or captured at the register |
| Shopper capture | Name, email, phone, ZIP: only the fields the organizer has enabled, and only what a shopper chooses to give | Offered at the register, always optional |
| Consent records | Whether marketing consent was given or withdrawn, when, and the exact wording displayed at the time | Recorded automatically when consent changes |
| Technical and security | IP address, request timestamps, error and audit logs, failed-login records | Collected automatically as you use the Service |
What we deliberately do not collect
- No card numbers. Payments go directly to Stripe.
- No advertising or cross-site tracking. We run no ad networks, no tracking pixels, and no third-party analytics that profile you across other websites.
- No sale of personal information. See Section 5.
- No location tracking beyond the coarse IP address in our security logs.
3. Why we use it
- To provide the Service: run your events, sync your registers, compute payouts, generate tags and reports.
- To send transactional messages: receipts, drop-off and pickup reminders, verification codes, and account notices. These are not marketing and you cannot opt out of them while you have an account.
- To bill you for the events you publish.
- To secure the Service: rate limiting, abuse detection, audit trails, and investigating incidents.
- To support you when you contact us.
- To meet legal obligations, including keeping proof of consent and of your acceptance of our Terms.
We do not use Customer Data to train machine-learning models, and we do not use it to build profiles for advertising.
4. Marketing email and CAN-SPAM
Marketing email sent through CircaSale is sent by the organizer, to people who opted in through the organizer. Every such message carries an unsubscribe link, the organizer's postal address, and one-click unsubscribe headers, because the CAN-SPAM Act requires them. The Service refuses to send marketing mail for an account with no postal address on file.
Consent is opt-in and off by default. It is never bundled with the receipt request, and it is never a condition of a payment. Each grant or withdrawal is recorded with the wording exactly as it was displayed. An unsubscribe is permanent: a later purchase does not re-subscribe anyone.
If we send our own marketing email to organizers, the same applies and the unsubscribe link in that message is the way to stop it.
5. Who we share it with
We do not sell personal information, and we do not share it for cross-context behavioral advertising, as those terms are used in US state privacy laws. We have never done so.
We share information with:
- Service providers who host, store, deliver, and process on our behalf under contract. The current list is at circasale.com/subprocessors.
- Your own organization: other users on your account see the account's data according to their role.
- Legal requests: when we are required by law, subpoena, or court order, or to protect the rights and safety of our users. Where we may lawfully do so, we will tell you first.
- A successor in a merger, acquisition, or sale of assets. This policy continues to apply until it is replaced with notice.
6. How long we keep it
- Account and sale data: for as long as your account is open. After it closes, you have ninety (90) days to export, and then we may delete it.
- Consent and agreement records: kept beyond account closure, because their purpose is to evidence what was agreed and when.
- Unsubscribe records: kept indefinitely. Deleting them is what would cause someone to be emailed again.
- Security and audit logs: retained on a rolling basis, typically twelve (12) months.
- Billing records: retained as long as tax and accounting law requires.
7. Your rights
Depending on where you live in the United States, you may have the right to know what personal information we hold, to get a copy of it, to correct it, to delete it, to opt out of sale or sharing (we do neither), and not to be discriminated against for exercising these rights. Some states also give you a right to appeal a decision we make about your request.
If you are a consignor, volunteer, or shopper, contact the organizer running your sale; they control your record and their dashboard has export and delete tools built in. If you cannot reach them, write to us and we will help.
If you are an organizer, most of what you need is in your dashboard. For anything else, write to [PRIVACY EMAIL].
We will acknowledge a request within ten (10) business days and respond substantively within forty-five (45) days, extendable once by another forty-five (45) days where the law allows. We will verify your identity before acting, and we may decline a request we cannot verify or that the law does not require us to honor, and we will tell you why. Using an authorized agent is fine; we will ask for proof of authority.
8. Cookies
We use the minimum a site like this needs, and no more:
- Session cookies that keep you signed in to the documentation site.
- Local browser storage that holds your login token so the dashboard and portal do not sign you out on every page load. Impersonation sessions use session storage instead, and end when the tab closes.
All of these are strictly necessary to provide something you asked for. We use no advertising cookies, no analytics cookies, and no third-party trackers, which is why you will not find a cookie consent banner on this site. Clearing your browser storage signs you out.
9. Security
Passwords are hashed with bcrypt and never stored in plain text. Traffic is encrypted in transit. Each organization's data is scoped to its own account and separated at the query level. Access is role-based, administrative access is logged, and support sessions that view an account are read-only and cannot change anything.
No system is perfectly secure. If we discover a breach affecting your personal information, we will notify you and any regulator as required by applicable state law, without unreasonable delay.
10. Children
The Service is for adults running consignment sales. It is not directed to children, and we do not knowingly collect personal information from anyone under 13.
Because these are often children's-goods sales, the inventory naturally describes items in children's sizes. That data is about the items, not about identified children: no child's name, age, or contact details are collected as part of an inventory record. Organizers must not enter a child's personal information into an item description or any other field. If we learn we have collected personal information from a child under 13, we will delete it; contact [PRIVACY EMAIL].
11. Changes to this policy
We may update this policy. When we do, we will change the version and effective date at the top. If a change materially affects how we use personal information, we will give at least thirty (30) days' notice by email to account holders before it takes effect.
12. Contact
Privacy questions and requests:
[LEGAL ENTITY NAME]
[POSTAL ADDRESS]
[PRIVACY EMAIL]