Legal
Privacy Policy
What we collect, why, and what rights you have over it.
Circle 26 works with families whose affairs are private by nature. This policy explains what we collect through our website, why, how long we keep it, and what you can ask us to do about it. It is written to be read, not to be skimmed past.
If anything here is unclear, write to us at legal@circle26.com and we will answer.
1. Who we are
Circle Family Office Pte. Ltd. ("Circle 26", "we", "us") is the data controller for personal data collected through circle26.com.
| Registered entity | Circle Family Office Pte. Ltd. |
| Company number | 202526403M |
| Registered office | 160 Robinson Road, #14-04 SBF Centre, Singapore |
| Privacy contact | legal@circle26.com |
We are established in Singapore. Because we offer services to people in the United Kingdom and the European Economic Area, the UK GDPR and the EU GDPR apply to our processing of their personal data, alongside Singapore's Personal Data Protection Act 2012.
Our representative. [Where required under Article 27 UK GDPR and Article 27 EU GDPR, our representative in the United Kingdom is [●] and our representative in the European Union is [●]. You may contact them on any matter relating to our processing of your personal data.]
2. What we collect, and why
We collect personal data in five situations. Each has its own purpose, its own legal basis and its own retention period.
2.1 When you contact us or apply to work with us
What we collect. Your name, email address, telephone number, the organisation or family office you represent, the country or countries you operate in, and whatever you choose to tell us in the message or application. Our application form also asks for an indicative wealth level and the jurisdictions your affairs touch.
Why. To respond to you, to assess whether we are the right fit, and to prepare for a first conversation.
Legal basis. Steps taken at your request before entering into a contract (Article 6(1)(b)), and our legitimate interest in responding to enquiries about our services (Article 6(1)(f)).
A note on the application form. We ask for an indicative wealth level and jurisdictions because they determine whether we can help you and what an engagement would involve. We ask for a band, not a number. We do not ask for account details, entity names, holdings or the identity of family members at this stage, and we would ask you not to provide them. If you would rather discuss this by telephone than in a form, say so and we will arrange it.
How long we keep it. Twelve months from your last contact with us if the enquiry does not proceed. Where an engagement follows, for the duration of that engagement and for seven years afterwards, in line with our professional and record-keeping obligations.
2.2 When you book a Wealth Clarity Session
What we collect. Your name, email address, the session date and time you select, and any information you provide in advance of the session. Payment is taken through Stripe.
Card details never reach us. Payment is processed by Stripe using their hosted payment interface. Your card number, expiry date and security code are entered directly into Stripe's systems and are never transmitted to, stored on or accessible by Circle 26. We receive confirmation that a payment succeeded, the amount, the currency and the last four digits of the card.
Why. To provide the session you have booked, to take payment, and to meet our accounting and tax obligations.
Legal basis. Performance of a contract with you (Article 6(1)(b)), and compliance with a legal obligation in respect of financial records (Article 6(1)(c)).
How long we keep it. Session records for the duration of any resulting engagement and seven years afterwards. Payment records for seven years, as our accounting obligations require.
What is discussed in a session is confidential and subject to the Chatham House Rule. It is governed by the engagement terms and the non-disclosure agreement that accompany that service, not by this policy.
2.3 When you use the Wealth Clarity Assessment
The Wealth Clarity Assessment at circle26.com/assessment is a thirty-question self-assessment that produces a profile on screen.
Your answers stay in your browser. The assessment runs on your own device. Your answers are not transmitted to us and we do not see them, unless you choose to ask for the written profile.
If you ask us to send you the profile, we collect your email address and, at that point, the answers needed to produce the document. We use them to generate and send your profile.
Legal basis. Your consent (Article 6(1)(a)). You may withdraw it at any time by writing to us, and withdrawal does not affect anything we did before you withdrew.
How long we keep it. Your email address and profile for twenty-four months, unless you ask us to delete them sooner or you subscribe to The Coordinator, in which case your email address is retained on that basis until you unsubscribe.
2.4 When you download the Lean Family Office Guide
Where this happens. The guide is delivered through a form hosted by HubSpot, not on circle26.com. You are taken to a HubSpot page, and the information you give is collected there. Circle 26 remains responsible for that information and for what happens to it afterwards.
What we collect. Your name, email address, and any other field the form asks for. HubSpot's document viewer also records that the guide was opened, which pages were viewed and for how long.
Why. To send you the guide, and to understand which parts of it people actually read so we can improve it.
Legal basis. Steps taken at your request before entering into a contract, and our legitimate interest in understanding how our published material is used (Article 6(1)(b) and 6(1)(f)).
How long we keep it. Twenty-four months from your last engagement with us, unless you subscribe to The Coordinator, in which case your email address is retained on that basis until you unsubscribe.
Downloading the guide does not subscribe you to anything. If the form offers you The Coordinator, that is a separate, unticked choice.
2.5 When you register for an event
We run online Expert Sessions and in-person Workshops.
What we collect. Your name, email address, the organisation or family office you represent, and the event you are attending. For in-person events we may also ask about accessibility requirements and dietary requirements.
Why. To register you, to send you joining details, and to run the event.
Legal basis. Performance of a contract with you, or steps taken at your request before entering into one (Article 6(1)(b)).
Accessibility and dietary information. These fields are optional. Dietary requirements can reveal information about health or belief, so we treat them with particular care: we use them only to cater the event you are attending, we do not add them to your contact record, and we delete them within thirty days of the event. Where you provide such information, you consent to our using it for that purpose (Article 9(2)(a)), and you can withdraw that consent at any time.
Other attendees. Whether an event is online or in person, other attendees can see who is present — your name, and whatever you have set as your display name. We do not circulate an attendee list, and we do not share your details with other attendees or with speakers unless you ask us to.
Recording. Expert Sessions and Workshops are recorded, and we say so before each session begins. Recordings are made available to Circle 26 members through our membership platform and remain available to members who join later. If you attend and speak, your voice, your name and anything you contribute form part of that recording. If you would prefer not to be recorded, attend without your camera and microphone on and use the written questions instead, or let us know in advance.
Chatham House Rule. Sessions are held under the Chatham House Rule: what is said may be used, but not attributed. Members agree to that rule and to our Community Charter as a condition of membership.
How long we keep it. Registration records for twenty-four months. Accessibility and dietary information for thirty days after the event.
2.6 When you subscribe to The Coordinator
What we collect. Your email address, and your name if you give it. We record when you subscribed, and whether you open or click the emails we send.
Why. To send you The Coordinator, our newsletter on running a Lean Family Office.
The Coordinator is our only newsletter. Networth, published at networth.pro, is a personal publication of a member of our team. It is operated separately, has its own privacy notice, and is not covered by this policy.
Legal basis. Your consent (Article 6(1)(a)).
How long we keep it. Until you unsubscribe, and for twelve months afterwards so that we can honour your unsubscribe request. Every email we send carries a one-click unsubscribe link.
Subscribing is always separate. We will not add you to The Coordinator because you contacted us, downloaded the guide, registered for an event, booked a session, completed the assessment or became a client. It only happens if you ask for it, as a choice of its own, on a box that is never pre-ticked.
2.7 When you visit the website
We use analytics to understand how the site is used and where it falls short. This is covered in section 4 and in our Cookies Policy.
3. Members of the Blueprint and Peer Circle
Our membership community runs on Circle.so, a separate platform, not on circle26.com.
We are the controller for the member data you provide to us and for the content you post within our community — your profile, your posts, your comments and your participation.
Circle.so is our processor for that data, and processes it on our instructions under a data processing agreement.
Circle.so is also an independent controller for its own platform usage and product data. That processing is governed by Circle.so's own privacy notice, not by this policy, and we do not control it.
What members should know. Content you post is visible to other members of the community. Our Community Charter and Terms of Use govern what may be shared and the confidentiality expected of everyone in it. Do not post information about a family, a structure or a transaction that you are not free to share.
Membership data is retained for the duration of your membership and for twelve months afterwards.
4. Cookies, analytics and session recording
We do not use analytics or recording of any kind until you consent through the banner on our site. Necessary cookies, which make the site function, run without consent because the site cannot work without them.
Subject to your consent, we use:
| TOOL | PROVIDER | WHAT IT DOES |
|---|---|---|
| HubSpot | HubSpot, Inc. | Analytics, form handling, email delivery, and recording which pages and documents you view |
| Google Analytics | Aggregate statistics on how the site is used | |
| Microsoft Clarity | Microsoft | Session recording and heatmaps — see below |
| Google Tag Manager | Manages how the tools above are loaded |
Microsoft Clarity records your session. It captures how you move through a page — mouse movement, scrolling, clicks and navigation — and allows us to replay it so we can see where the site is confusing or broken. Text you type into forms is masked and is not captured.
We do not run session recording on our assessment or application pages at all. Microsoft Clarity is disabled entirely on those pages, so nothing you enter there is recorded, replayed or transmitted to Microsoft.
We use session analytics to improve the site, not to identify or profile any individual, and we do not attempt to link a recording to a named person.
If you would rather we did not, decline analytics cookies in the banner, or change your choice at any time through the cookie settings link in our footer. The site works fully either way.
Our Cookies Policy lists every cookie, its purpose and its duration.
5. Who we share your data with
We do not sell personal data. We do not share it for anyone else's marketing.
We use the following service providers, each under a written data processing agreement:
| PROVIDER | PURPOSE | DATA LOCATION |
|---|---|---|
| HubSpot | Forms, contacts, email, website and document analytics | European Union |
| Stripe | Payment processing | United States |
| Circle.so | Membership community platform | United States |
| Website analytics and tag management | United States | |
| Microsoft | Session analytics; business email, documents and file storage | Singapore and United States |
| Notion Labs | Project management and meeting notes | European Union |
We may also share personal data with our professional advisers where necessary, and with a regulator, court or authority where we are required by law to do so. If our business is transferred, personal data may transfer with it, and we would tell you before that happened.
6. Sending data outside the UK and Europe
Circle 26 is established in Singapore, and some of our providers are in the United States. Neither Singapore nor the United States has an adequacy decision covering all such transfers.
Where personal data protected by the UK GDPR or EU GDPR is transferred to us or to a provider outside the UK or the EEA, we rely on:
- the UK International Data Transfer Agreement, or the Addendum to the EU Standard Contractual Clauses, for transfers subject to UK law; and
- the EU Standard Contractual Clauses approved by the European Commission, for transfers subject to EU law,
together with the additional technical and organisational measures described in section 7.
You may ask us for a copy of the safeguards that apply to a particular transfer by writing to legal@circle26.com.
7. How we protect your data
Access to personal data is limited to those of our people who need it. Working copies are encrypted at rest on every device we use. Accounts carrying access to personal data require multi-factor authentication. Access is reviewed whenever someone joins or leaves, and removed within one working day of a person ceasing to need it.
We ask only for the data we need. Where we can work with a band rather than a figure, or a category rather than a name, we do.
No system is perfectly secure, and we do not claim otherwise. Where a breach affects your personal data and is likely to result in a risk to your rights, we will notify the relevant supervisory authority and, where the risk is high, you.
8. Artificial intelligence
We do not use your personal data to train any artificial intelligence model.
Some of the business systems we use — those listed in section 5 — include automated or AI-assisted features as part of their standard functionality. Where a provider offers business or enterprise terms under which customer content is not used to train their models, we select those terms.
We do not submit personal data to general-purpose consumer AI services.
Our full position is set out in our AI Policy.
9. Your rights
Wherever you are, you may ask us to:
- tell you what personal data we hold about you, and give you a copy
- correct anything inaccurate or incomplete
- delete it, where we have no continuing reason to hold it
- restrict how we use it while a question about it is resolved
- transfer it to you or another provider in a machine-readable format
- stop using it, where we rely on legitimate interests
- withdraw consent at any time, where consent is what we rely on
To exercise any of these, write to legal@circle26.com. We will respond within one month. We do not charge for this, and we will not ask why.
If you are unhappy with how we have handled your data, tell us first — we would rather fix it. You also have the right to complain to a supervisory authority:
- United Kingdom — Information Commissioner's Office, ico.org.uk
- European Economic Area — the supervisory authority in the country where you live or work
- Singapore — Personal Data Protection Commission, pdpc.gov.sg
10. Automated decisions
We do not make decisions about you by automated means alone, and we do not profile you in any way that produces legal or similarly significant effects.
The Wealth Clarity Assessment scores the answers you give it and returns a profile. It is a self-assessment tool. It does not decide anything about you, it produces no outcome other than the profile you see, and no one at Circle 26 acts on it unless you send it to us and ask us to.
11. Children
Our services are for adults. We do not knowingly collect personal data from anyone under 18. If you believe we have, tell us and we will delete it.
12. Links to other sites
Our site links to other websites, including Circle.so. We are not responsible for their privacy practices, and this policy does not cover them.
13. Changes to this policy
We will post any change here and update the date at the top. Where a change materially affects how we use your personal data, we will tell those affected directly.
14. Contact
| Privacy enquiries | legal@circle26.com |
| Post | Circle Family Office Pte. Ltd., 160 Robinson Road, #14-04 SBF Centre, Singapore |
| UK representative | [●] |
| EU representative | [●] |