Privacy Policy — Circle

Last updated: October 15, 2026

ZINKEY LLC ("Zinkey Labs", "we", "us") publishes the mobile game Circle ("the App"). This Privacy Policy explains what data the App processes, why, who it is shared with, and the rights you have. It is written to comply with the EU General Data Protection Regulation (GDPR) and applicable Apple App Store and Google Play requirements.

Data controller

The data controller is ZINKEY LLC, publisher of the App. For any privacy-related request, contact privacy@zinkeylabs.com.

No account, no identity

The App never asks for your name, your email address or a password. When you first open it, your phone generates a random secret and keeps it in the device's secure storage. Our server only ever sees a one-way hash of that secret, which it uses to recognise the device and nothing else. We cannot link it to you, and we cannot recover it if the device is lost.

What stays on your phone

Your game profiles (display name, handle, biography, photo), your worlds, the characters in them, your posts, your private messages and your notifications are stored locally on the device. They are not uploaded to us and we have no way to read them — the one exception is a world you choose to share with the community, described below. Deleting a profile in the App, or uninstalling the App, deletes them permanently, including for us, because we never had them.

What is processed, and by whom

Diagnostic and usage data never contains the text of your games. Your profile photo stays on the device and is not sent to the model provider. A photo you attach to a post or a private message is sent to it once, to be described in words, so the characters can react to it. The photo of a character you create, and the cover of a world, are sent to the moderation when you save them. A photo you give a character of a world you share is sent to our server with that world.

What is sent to the model provider

For the characters to answer, the App sends the text they need to read — the relevant posts and conversations, and your game profile — to the model provider. These transmissions serve only to generate the reply; we do not use them to train anything and we do not keep a copy.

Do not type sensitive personal information into the game. Whatever you write in a post or a private message, and any photo you attach to one, is transmitted like the rest. The model provider applies its own retention policy to the requests it receives; please refer to it for how long it keeps them.

Automatic moderation

Before a character or a world you create is saved, its texts and its photo are sent to OpenAI's moderation service, which answers whether they contain sexual, hateful or violent content. We only use that answer: we keep no copy of what was sent, and OpenAI does not use it to train its models. OpenAI may keep the request for up to 30 days to detect abuse, then deletes it.

Worlds you share with the community

A world you create stays on your phone, unless you choose to share it with the community. If you do, we receive what you wrote for it — its name, its description, its cover, and its characters as you wrote them (name, gender, age, biography, personality), with the photos you gave them. It is stored on our server under the anonymous identifier of your account and reviewed by us before it is listed. Once accepted, it is shown to other players, who can play in it. We count how many games are started in each shared world and show that number.

Any player can report a community world, or hide every world of its creator without reporting anything. A report keeps the reason chosen, the note if one was written, and the anonymous identifier of the account that sent it, so that we can look into it and stop showing that creator's worlds to the person who reported them. Hiding a creator keeps the anonymous identifiers of both accounts, and nothing else, so that their worlds are no longer shown. Do not put real, identifiable people, or their photos, in a world you share.

Purchases

Payments are processed by the App Store or Google Play. We never receive your name, your address or your card details — only the confirmation that a subscription is active, its plan and its end date, so that Circle+ can be turned on. Subscriptions are validated through RevenueCat under the anonymous identifier of your account.

Legal basis

• Performance of the service — the data strictly needed to make the game work: the day's energy, the Circle+ subscription, the text sent for a generation, purchase validation, and the hosting of a world you ask us to share.
• Legitimate interest — crash reports, anonymous usage measurement, the automatic moderation of characters and worlds, the review of shared worlds and of the reports sent about them, and hidden creators, kept proportionate.
• Consent — advertising attribution (AppsFlyer, only after you allow tracking), push notifications, and access to your photo library and camera, which you can grant or refuse at any time in your device settings.

Data sharing

We do not sell your data and there is no advertising in the App. The only advertising-related tool is AppsFlyer, which measures where installs come from and runs only if you allow tracking when the App asks. Data is shared only with the providers listed above, acting as processors on our behalf. Some of them may process data outside the European Union; where that happens, appropriate safeguards such as Standard Contractual Clauses apply.

Retention

The server row holding your energy and your subscription status is kept as long as the device uses the App, and deleted on request. A shared world is kept until it is deleted, by us or at your request; deleting it removes its characters and their images too. A report is kept as long as it is needed to handle it. A hidden creator is remembered as long as both accounts exist. Game content is kept on your device for as long as you keep it. Diagnostic data is retained for a limited period defined with each provider.

Your rights

You may delete a profile at any time from inside the App, and erase everything on your phone by uninstalling it. To remove a world you shared, write to privacy@zinkeylabs.com with its name. Under the GDPR you also have the right to access, rectify, delete, restrict and object to the processing of your data, and the right to data portability. To exercise these rights, write to privacy@zinkeylabs.com — note that, since we hold no identifying data, we may need the device to prove it holds the secret in order to act on the matching account. You also have the right to lodge a complaint with your national data protection authority.

Children

The App is intended for players aged 17 and over. We do not knowingly collect data from children under that age.

Changes to this policy

We may update this Privacy Policy. The "Last updated" date at the top of this page reflects the latest version. Material changes will be communicated within the App where appropriate.

Contact

For any question about this policy: privacy@zinkeylabs.com