SECTION 1: GENERAL
The OurCircle Application (“OurCircle” or “Application”) is a product of FaceGuard, LLC
(“Company”). The Company respects the privacy of its users (“user” or “you”) who benefit from the
OurCircle Desktop and/or Mobile Applications and accordingly employs methods and procedures
applicable to best protect the security of our users.

SECTION 2: FUNCTION
OurCircle makes it easy for like-minded people to connect and share information. It provides simple,
powerful tools to gather documents, photos, and ideas from anywhere, and to create notes, files, and
rich content all in one place. Plus, OurCircle is automatically secure and spam-free by design.

Storing data in the cloud is naive — once it’s on someone else’s servers, it can be sold, subpoenaed, or
surrendered to political whim. FaceGuard, LLC is not a cloud storage provider, and we neither hold nor
sell your personal information. OurCircle keeps your content exactly where it belongs — on your
device, encrypted, and accessible only to you and the people you choose to share it with. Content
outside of OurCircle is not protected by this Policy.

OurCircle offers enhanced editing controls for Notes, Images, and Rays. You may also import content
from your Device or Camera, the Internet, or content Shared from a Paired device.
Each piece of content is individually encrypted — visible only to you, the people you choose to share it
with, and no one else. You’re always in control: a circle is a community formed by invitation only, and
all participants are aware of that privilege. Anyone who violates that trust may be instantly rejected,
and a contrite offender can be individually reinstated.
Bonus: FaceGuard’s innovative cognitive access option is seamlessly incorporated as an enhancement
for those who prefer authenticating their identity in seconds, using a lifetime of unforgettable
memories.

SECTION 3: TYPES OF DATA
This Privacy Policy is intended to inform you, among other things, about the following categories of
data.

Account & Authentication Data To create and secure your account, we collect the email address you
provide. If you use FaceGuard as your authentication method, this may also include face-recognition
challenge data — handled under FaceGuard’s own privacy terms, not stored as part of your OurCircle
content.

Optional Profile Data OurCircle also provides optional fields where you may choose to enter
additional personal information (see Section 4, “User Data — Personal,” for the full list of fields).
Entering this information is entirely discretionary, and it is stored under the same local, encrypted, on-
device architecture described throughout this Policy.

Device Data We collect limited technical information necessary to run the app and keep it working
properly — device type, operating system version, and app version. This is used for compatibility,
troubleshooting, and security patching, not for tracking your activity.

Encrypted Content in Transit When you share content with someone in your circle, encrypted data
passes through our servers to reach their device. We see this only as encrypted, unreadable data —
never as plaintext, and never in a form we can open. (See Section 6, “Transfer,” for how this data
moves between devices.)

Payment & Subscription Data If you subscribe to a paid tier or professional plan, payment processing
is handled by a third-party processor. We do not store your full payment details ourselves.

We Do Not Sell Your Data The Company does not sell or share your personal information for cross-
context behavioral advertising, and we do not intend to do so in the future.

What We Don’t Collect

• Your content. Notes, documents, photos, and files you create or import stay encrypted on your
device. We never see them, store them in plaintext, or have the ability to decrypt them.

• Your keys. Encryption keys used to protect your data are never transmitted to or stored by us.

• Your activity within the app. We don’t track what you read, write, or share, or build
behavioral profiles from your usage.

• Your contacts or circle membership details, beyond what’s technically required to route
encrypted data between paired devices.

SECTION 4: USER DATA — PERSONAL
While using the Application, OurCircle provides Author fields allowing users to enter certain
personally identifying information (“Personal Data”). Entering this information is entirely
discretionary.

Personal Data is stored locally on the drive of the user’s device(s) and is encrypted, and is
not persistently stored in any cloud service the Company controls. When Personal Data is shared with a
paired device, it transits our servers only in fully encrypted form, as described in Section 6, “Transfer.”
Personal Data entered by users may include, but is not limited to, the following:

• First Name
• Middle Initial
• Last Name
• Birth Date
• Gender
• Email Address(es)
• Physical Address (City, State, ZIP, Country)
• Phone Number(s) (Mobile/Work/Home)
• Digital Signature
• Photo Avatar

SECTION 5: OUR APPROACH TO PRIVACY
Most services ask you to trust that they won’t look at your data. OurCircle is built so that we structurally can’t.

Your personal database lives encrypted on your own device — not on our servers, not in a cloud
backup we control. Unlike systems that rely on a single, fixed encryption key sitting somewhere
waiting to be used, your database has no static master key an employee could retrieve, no backdoor,
and no internal process that lets us view your content, whether encrypted or decrypted. This isn’t a
policy promise — it’s how the system is built. OurCircle employees cannot unencrypt your personal
database, on this device or any other, because we simply don’t hold the means to do so.

OurCircle also helps you stay secure from the start. Directly on your device, you can create your own
passcode or let OurCircle generate one for you — either way, nothing less than 16 characters,
combining uppercase and lowercase letters, numbers, and symbols.

SECTION 6: TRANSFER
Application access to user device(s) is restricted. That said, OurCircle does enable Public Key/Private
Key (PKI) encrypted data exchange between devices manually paired by the user, in two forms:

1. SYNC — small, non-identified data only.
2. REPLICATE — user-identifiable data; however, the file is encrypted such that it is only
accessible by the paired device holding the correct Public Key/Private Key. The AWS platform
through which this exchange occurs is itself secured — see Section 10, “Service Providers,” for
detail.

SECTION 7: DATA RETENTION
Personal Data and Document Data (defined as content imported, generated, and/or stored within Notes,
Images, PDFs, and Rays) stored locally on the user’s device(s) continues to be stored there at the user’s
discretion. Users may delete Personal Data and/or Document Data whenever they deem it necessary.

SECTION 8: SECURITY
The Company and the Application employ exemplary measures to secure the user’s personal and
document data against breach by an unauthorized party. That said, even the best security measures
cannot fully eliminate all risks given enough time and resources. We are therefore not responsible for
any third-party circumvention in which an unauthorized person gains — or is granted by the user —
access to the local device on which the Application is installed.

SECTION 9: SERVICE PROVIDERS
The Company employs Amazon Web Services (AWS) to facilitate the encrypted transfer of data
between user devices. AWS never has access to your Personal or Document Data in a decrypted,
readable form. Amazon Web Services is governed by its own Privacy Policy and Terms and
Conditions. AWS’s commitment to security is well documented at:
https://aws.amazon.com/compliance/data-privacy-faq/?nc1=h_ls

SECTION 10: PAYMENT PROCESSORS
The Company employs the following third-party payment gateways:
• Apple Store
• Google Store
• Microsoft Store
Should you initiate an optional purchase, you will be directed to the secure servers of the applicable
third-party payment processor. Your name, billing address, e-mail address, phone number, and credit
card number may be required. This information is used by the payment gateway to process financial
transactions. Third-party service vendors are governed by their own privacy policies, terms, and
conditions.

SECTION 11: LINKS TO OTHER SITES
OurCircle may contain links to partner websites that are not operated by us. We strongly advise you to
review the Privacy Policy of every website you visit, as OurCircle has no control over, and assumes no
responsibility for, the content, privacy policies, or practices of any third-party websites.

SECTION 12: PRIVACY RIGHTS
(a) European Economic Area (EEA) Users. If you reside in the EEA, OurCircle abides by the
principles and regulations of the General Data Protection Regulation (GDPR). You have the right to:
access the personal data we hold about you; request correction or deletion of that data; restrict or object
to its processing; receive a copy of your data in a portable format; and lodge a complaint with your
local data protection supervisory authority. Because Company servers are located in the United States,
any Personal Data that transits our servers in encrypted form as described in Section 6 may be
transferred outside the EEA; where this occurs, we rely on appropriate safeguards, such as Standard
Contractual Clauses, to protect that transfer.

(b) California Users. If you are a resident of California, United States, OurCircle abides by the
principles and regulations of the California Consumer Privacy Act (CCPA/CPRA). You have the right
to: know what personal information we collect; request deletion of your personal information; correct
inaccurate personal information; opt out of the sale or sharing of personal information (see Section 3,
“We Do Not Sell Your Data”); and not be discriminated against for exercising these rights.

(c) Exercising Your Rights. To submit a request regarding your personal data under GDPR, CCPA, or
any other applicable privacy law, contact us using the information in Section 15, “Contact Us.” We will
respond to verified requests within the timeframe required by applicable law.

(d) Children’s Privacy. OurCircle is not directed to children under the age of 13 (or the relevant
minimum age in your jurisdiction), and we do not knowingly collect Personal Data from children. If
you believe a child has provided us with personal information, please contact us so we can address it.

SECTION 13: CHANGES TO THIS PRIVACY POLICY
The Company may update this Privacy Policy from time to time. We will notify you of any changes by
posting the new Privacy Policy on the OurCircle website, which provides direct access to these pages
within the Application. Prior to any change becoming effective, we will update the “effective date” at
the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any
changes.

SECTION 14: CONTACT US
If you have any questions about this Privacy Policy, please contact us:
FaceGuard, LLC Address: 825 Highland Ave Ste 3E, Downers Grove, IL, 60515-1549, USA Contact
person: Robert S Hedin E-mail: bhedin@faceguard.co