Privacy Policy – Circular Health
Last Updated: 28 March 2025
Circular Health Ltd
Registered in Ireland
1. Who We Are
We are Circular Health Ltd, an Irish company committed to helping individuals navigate complex chronic illnesses such as Long COVID, ME/CFS, POTS, and MCAS.
This Privacy Policy outlines how we collect, use, and protect your personal data when you visit our website, join our waitlist, or use our app — in accordance with the General Data Protection Regulation (GDPR) and other applicable privacy laws.
2. What Data We Collect
📝 When You Join the Waitlist
When you sign up for early access via our waitlist (hosted on Typeform), we collect:
- Email address
- Self-reported experience managing your illness
- Your biggest current challenge (optional)
- Whether you'd like to join as an early beta tester
Some of this information may be considered health-related data under GDPR. We treat it with enhanced care and process it only with your explicit consent.
🌐 When You Visit Our Website
We collect basic analytics and performance data, including:
- IP address
- Browser and device type
- Pages visited and time spent
This information is collected through PostHog and Vercel Analytics to help us understand user behavior and improve our website. No invasive cookies or marketing trackers are used.
👤 When You Use the App (In the Future)
When our app is live and you create an account, we may collect:
- Name, email, and password
- Information you choose to share about your health journey
- App usage and engagement data
We will ask for clear consent before collecting any sensitive health information and will provide additional details at that time.
3. How We Use Your Data
We process your data to:
- Communicate product updates and send early access invitations
- Analyze anonymous insights to guide product development
- Improve website experience and platform functionality
- Provide personalized support within the app (once launched)
We do not:
- Sell or rent your personal data
- Use your information for third-party marketing
- Share your identifiable health data without your consent
4. Legal Basis for Processing
We rely on the following legal bases under GDPR:
- Explicit consent – for collecting and processing your waitlist and health-related responses
- Legitimate interest – to improve our product and understand user needs
- Contract – when you sign up for the app, we use your data to deliver the service
You may withdraw consent at any time by contacting us at privacy@joincircular.com.
5. How and Where Data Is Stored
We take strong steps to protect your data and store it using secure, privacy-focused tools:
Typeform
For waitlist submissions
PostHog and Vercel Analytics
For website analytics
Google Workspace
For internal communications
Notion
For anonymized research notes only
We do not store identifiable health-related data in Notion or Google Workspace.
Sensitive health data will be stored in HIPAA-ready infrastructure, with appropriate safeguards and access controls. We are actively working to ensure all processing environments meet both GDPR and health privacy standards.
6. Who Can Access Your Data
Your data is accessible only to authorized members of the Circular Health team. Where third-party services are used (e.g., analytics or form tools), we ensure they meet strong privacy and security standards, and we sign Data Processing Agreements (DPAs) or Business Associate Agreements (BAAs) where required.
7. Your Rights Under GDPR
Access your personal data
Request a copy of all data we hold about you
Correct inaccurate or incomplete data
Update your information at any time
Withdraw consent at any time
Opt out of data processing based on consent
Request deletion of your personal data
Exercise your "right to be forgotten"
Object to or restrict data processing
Limit how we use your data
Lodge a complaint
Contact your local Data Protection Authority
To exercise your rights, contact us at: privacy@joincircular.com
8. Data Retention
Waitlist data
Stored for up to 12 months or until product invitations are sent
Analytics data
Retained for up to 12 months in anonymized or aggregated form
App account data
Will be stored as long as your account is active (subject to app-specific data retention policy at launch)
9. Future Updates
We may update this Privacy Policy as our services evolve. If we make significant changes, we will notify users via email or on our website, and seek renewed consent if required.
10. Contact Us
For questions or concerns about this Privacy Policy:
Circular Health Ltd