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Privacy Policy

Last modified on 19 May, 2026

1. Introduction

This Privacy Policy explains how SigmaHorse LLC ("SigmaHorse," "we," "us," or "our") collects, uses, shares, and safeguards information in connection with the CircleUp mobile application, website at circleup.now, and related services (collectively, the "Service"). The Service helps managers share short videos with their teams and lets employees get role-aware answers through an AI assistant ("AI Assistant").

CircleUp is generally provided to employer organizations ("Customers") for use by their employees, contractors, and other authorized personnel ("End Users"). For most workplace data processed through the Service, the Customer is the controller and SigmaHorse is the processor / service provider acting on the Customer's instructions. This Policy describes SigmaHorse's own privacy practices; the Customer's policies will also govern how it uses information collected through the Service.

2. Information We Collect

2.1 Information you provide directly.

  • Account information: name, work email, phone number, profile picture, job title or role, workspace and team assignments, and authentication credentials.
  • Customer Content: video and audio recordings, attachments and files, written messages, AI Assistant prompts and chat history, questions escalated to managers, and feedback or reactions submitted within the Service.
  • Support and communications: messages you send to us, survey responses, and other information you choose to share.

2.2 Information collected automatically.

  • Usage data: features accessed, videos viewed, watch progress, questions asked, links followed, timestamps, and session activity.
  • Device and technical data: device type and identifiers, operating system and version, app version, language, time zone, mobile network information, crash and diagnostic logs, and IP address.
  • Cookies and similar technologies: on our website, we use cookies, SDKs, and similar technologies for authentication, security, analytics, and preferences. You can manage cookies through your browser or device settings.

2.3 Information generated from Customer Content.

When you submit Customer Content, the Service may generate derived data such as audio transcripts, language detection, content embeddings (vector representations used for retrieval), and AI Assistant responses. We treat this derived data as Customer Content.

2.4 Information from third parties.

If your organization uses single sign-on or directory services to provision accounts, we receive limited profile and role information from those providers as configured by the Customer.

3. How We Use Information

We use information to:

  • Provide, operate, and maintain the Service, including video playback, transcription, AI Assistant responses, escalation routing, and notifications.
  • Authenticate users, secure accounts, prevent fraud, and investigate misuse of the Service.
  • Respond to support requests and communicate with you about the Service.
  • Monitor, analyze, and improve the Service, including diagnosing errors and developing new features.
  • Generate aggregated or de-identified statistics that do not identify any individual or workspace.
  • Comply with legal obligations, enforce our Terms, and protect the rights, safety, and property of SigmaHorse, our users, and the public.

We do not use Customer Content to train general-purpose foundation models, and we contractually prohibit our AI subprocessors from doing so, unless we have obtained the relevant Customer's prior written consent.

4. AI Processing and Subprocessors

To deliver the AI Assistant and related features, we send portions of Customer Content (including transcripts, prompts, retrieved video segments, and contextual metadata) to third-party AI model providers and speech-to-text services that act as our subprocessors. These providers are bound by written contracts that:

  • Restrict their use of Customer Content to providing services to SigmaHorse;
  • Prohibit them from training or improving general-purpose models on Customer Content without consent;
  • Require appropriate technical and organizational security measures; and
  • Require deletion or return of Customer Content upon termination.

A current list of our subprocessors is available on request at support@circleup.now and, where required, will be provided to Customers under a data processing agreement.

AI Assistant responses may be inaccurate, incomplete, or out of date. Do not rely on them for legal, medical, safety, or other professional advice.

5. How We Share Information

We share information only as described below.

5.1 Within your workspace. Your name, profile picture, job title or role, posts, questions, AI Assistant interactions when shared, and escalations are visible to other members of your workspace consistent with the workspace's role and visibility settings. Workspace administrators may access, export, and delete End User account information and Customer Content within their workspace.

5.2 Service providers and subprocessors. We share information with vendors that help us operate the Service, including cloud hosting, content delivery, video transcoding, speech-to-text, AI model inference, analytics, error monitoring, and customer support. These vendors are bound by confidentiality and data-protection obligations.

5.3 Legal and safety. We may disclose information if we believe in good faith that disclosure is required by law, regulation, legal process, or government request, or is necessary to protect the rights, safety, or property of SigmaHorse, our users, or the public.

5.4 Business transfers. If we are involved in a merger, acquisition, financing, reorganization, or sale of assets, information may be transferred as part of that transaction, subject to commercially reasonable confidentiality protections.

5.5 With your consent. We may share information for other purposes with your consent or at your direction.

5.6 SMS and mobile information. Mobile information collected through SMS communications — including phone numbers entered for account verification or invitation acceptance — will not be shared with third parties or affiliates for marketing or promotional purposes. We may share this information with service providers solely for the purpose of delivering SMS messages you have requested or that have been initiated by your employer. Specifically, we use Amazon Web Services' End User Messaging service to send and verify SMS messages; AWS End User Messaging acts as a data processor under our direction, not as a third-party recipient. We do not engage in affiliate marketing, lead generation, or sale of mobile information. No mobile opt-in data is shared with third parties.

We do not sell personal information, and we do not share personal information for cross-context behavioral advertising.

6. Data Retention

We retain personal information and Customer Content for as long as needed to provide the Service and to fulfill the purposes described in this Policy, including to comply with legal obligations, resolve disputes, and enforce our agreements. Customer Content is retained according to the Customer's workspace configuration and our data processing agreement with the Customer. When you or your workspace administrator delete content or close an account, we delete or de-identify the associated data within a commercially reasonable period, subject to backup, security, and legal-hold exceptions.

7. Data Security

We use administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit and at rest for Customer Content, access controls, logging, and regular security reviews. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

8. Your Rights and Choices

Depending on your jurisdiction and your relationship to the Customer, you may have rights to:

  • access the personal information we hold about you;
  • correct inaccurate personal information;
  • delete personal information;
  • receive a copy of your personal information in a portable format;
  • object to or restrict certain processing;
  • withdraw consent where processing is based on consent; and
  • lodge a complaint with a supervisory authority.

For Customer Content and account information processed on behalf of an employer Customer, please direct rights requests to your workspace administrator; SigmaHorse will support the Customer in responding. For other requests, contact us at support@circleup.now. We will respond consistent with applicable law and may need to verify your identity.

You can also manage notification settings within the app and opt out of marketing emails through the unsubscribe link in any such email.

9. International Data Transfers

We operate primarily from the United States, and information we collect may be transferred to and processed in the U.S. or other countries where we or our subprocessors operate. Where required, we use lawful transfer mechanisms (such as the EU Standard Contractual Clauses) to safeguard cross-border transfers.

10. Workplace Privacy Notice

CircleUp is designed for workplace use. If you access the Service through an employer's workspace, your interactions on the Service (including videos, AI Assistant conversations, questions, and escalations) are visible to your employer consistent with applicable law and your employer's policies. You should not have an expectation of personal privacy in workplace communications conducted through the Service vis-à-vis your employer. Audio and video recordings may be subject to one-party or two-party consent laws; you are responsible for obtaining any consent required by the laws of the jurisdictions in which you record.

11. Children's Privacy and Minor Workers

The Service is designed for workplace use. The minimum End User age is 14, which aligns with the federal Fair Labor Standards Act's general minimum age for non-agricultural employment. The Service is not directed to children, and we do not knowingly collect personal information from anyone under 13. If we learn that we have collected personal information from a child under 13, we will delete it.

For End Users aged 14 to 17, the Customer (employer) is responsible for ensuring that (a) the minor's employment and use of the Service complies with applicable child labor laws, including any restrictions on hours, tasks, or workplace activities, and (b) any parental or guardian consent required by federal, state, or local law (including consent that may be required for an employer-managed account holding the minor's work-related communications) has been obtained. Workspace administrators are responsible for verifying that End Users meet these requirements before granting access.

12. California Privacy Notice

If you are a California resident, the California Consumer Privacy Act ("CCPA") gives you rights to know, delete, correct, and limit the use of your personal information, and the right not to be discriminated against for exercising those rights. We do not sell or share personal information for cross-context behavioral advertising. The categories of personal information we collect, the sources, purposes, and disclosures are described in Sections 2, 3, and 5 of this Policy. To exercise your rights, contact us at support@circleup.now. You may use an authorized agent; we may need to verify the agent's authority and your identity.

13. European Economic Area, United Kingdom, and Swiss Notice

If you are in the EEA, UK, or Switzerland, our legal bases for processing your personal information include performance of a contract with you or your employer, compliance with legal obligations, our legitimate interests (such as securing and improving the Service), and your consent where required. You have the rights described in Section 8 and the right to lodge a complaint with your local data protection authority. For most workplace data, your employer is the controller; please direct rights requests to your employer first.

14. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes we will provide notice through the Service or by other reasonable means and update the "Last modified" date above. Your continued use of the Service after the changes become effective constitutes your acceptance of the updated Policy.

15. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy, contact us at:

Email: support@circleup.now

SigmaHorse LLC