Privacy Notice

Diamond ltd, trading as Circle360 Empires, is the data controller for personal data processed through this service. This notice explains what we collect, why, and what rights you have.

Data we collect

• Account data — email address, password credentials, sign-in provider.
• Host verification data — full name, contact email, ID document type and number, and the image of your government-issued ID card.
• Event content — occasion details, guest names on invitation cards, setlists, and photos or videos added to the Moments wall.
• Support messages and any correspondence you send us.
• Technical data — device identifiers, IP address, and usage/telemetry.

Circle Pay wallet

If you use Circle Pay we process your Pay tag, optional phone number, wallet balances, transactions, deposits, withdrawals and rate alerts to run the wallet, prevent fraud and meet financial record-keeping duties. Card and bank payments are handled by our payment partner (Paystack); we never store full card numbers.

Location

With your permission we use your device location (or an approximate location from your IP address) to suggest nearby airports, hotels and your local currency. Location is used on your device and in the moment; you can deny or revoke permission in your phone settings at any time.

Contacts and camera

We do not upload your phone's contact list. If you choose to sync contacts or enter a phone number to find someone in Circle Pay, only the number you look up is checked. The camera is used only when you scan a QR code or take a photo you choose to post.

Why we use it, and our legal basis

• Creating and running your account and events — performance of our contract with you.
• Verifying host identity and preventing fraud or abuse — legal obligation and our legitimate interest in a safe platform.
• Customer support and service improvement — legitimate interests.
• Marketing emails, where sent — consent, withdrawable at any time.

Who we share it with

• Service providers and subprocessors that host, store and secure the platform.
• Paddle, our Merchant of Record, for sale of the Empire Pass and Empire Builder, payments, invoicing and tax compliance.
• Professional advisers such as legal and accounting.
• Authorities, where the law requires it.

We do not sell personal data.

ID documents

ID card images are stored in a private area that only you and our verification process can access. They are used solely to confirm you are a real, eligible host, and are deleted or anonymised once verification is complete or your account is closed.

Retention

We keep account and event data while your account is active and for a reasonable period afterwards to meet legal, tax and dispute obligations, then delete or anonymise it.

Security

We apply appropriate technical and organisational measures — encryption in transit, access controls, and row-level access rules so hosts can only reach their own records.

Your rights

Subject to your local law, you may request access, rectification, erasure, restriction, portability, object to processing, or withdraw consent. Where GDPR applies, you may also complain to your supervisory authority, and we will respond within one month. If data is transferred outside the UK/EEA, we rely on adequacy decisions or Standard Contractual Clauses.

Cookies

We use essential cookies and local storage to keep you signed in and remember your event draft. We do not use advertising cookies. You can clear them in your browser at any time.

Privacy questions: support@dspecial.app.