Before this page goes live, delete this box. This document was drafted from what the application's source code actually does. Every factual claim still needs checking against the finished product, and the bracketed items below must be filled in. It has not been reviewed by a lawyer.
Circle — Privacy Policy
Circle exists so that people can see what is happening to their goods, their money and their projects when they are not in the room. That only works if the record is honest — including the record of what we do with your information. This policy explains what we collect, why, and who else can see it.
1. Who we are
Circle is operated by Goshen Labs Ltd, based at House No. 20, Donut Street, Community 25, Tema, Greater Accra, Ghana. For the purposes of data protection law we are the data controller for the information described here. You can reach us at info@goshenlabs.tech.
Circle is used by people in Ghana and by Ghanaians living abroad. Where you are located outside Ghana, additional rights may apply to you under your local law, including the UK and EU General Data Protection Regulation. We describe those rights in section 8.
2. What we collect
| Category | Examples | Why we need it |
|---|---|---|
| Account information | Name, email address, phone number, profile photo, the role you hold in a circle | To create your account, sign you in, and show other members who they are dealing with |
| Ledger entries | Amounts, dates, descriptions, categories, the parties to a transaction | This is the core function of the product — an append-only record of money and goods |
| Evidence you attach | Photographs, receipts, invoices, delivery notes and other documents | To support entries in the ledger with proof that can be checked later |
| Voice notes | Audio you record inside the application | To let members explain an entry or a situation without typing |
| Meeting audio | Live audio while you are in a Circle meeting call | To transmit your voice to the other participants in real time |
| Device and diagnostic data | Application version, device type, operating system, error reports | To keep the application working and to investigate faults |
Permissions the application asks for
- Camera and photo library — only when you choose to attach an image or set a profile picture.
- Microphone — only when you record a voice note or join a meeting call.
- Files — only when you attach a document.
Declining a permission stops that specific feature from working. It does not prevent you from using the rest of the application.
3. What we do not do
- We do not sell your personal data. Not to anyone, under any circumstances.
- We do not use your data to serve you advertising, and we do not run third-party advertising networks inside Circle.
- We do not track you across other applications or websites.
- We do not record meeting call audio. It is transmitted live and not stored by us. [CONFIRM this remains true if recording is ever added.]
4. Who processes your data on our behalf
We use a small number of established service providers to run Circle. They process data on our instructions and are not permitted to use it for their own purposes.
| Provider | What it handles | Where |
|---|---|---|
| Supabase | Account authentication, the database holding your ledger, and storage of the files you upload | [CONFIRM your Supabase project region] |
| LiveKit | Real-time audio for meeting calls | [CONFIRM region] |
Because these providers operate internationally, your information may be stored or processed outside Ghana and outside your own country. Where that happens we rely on the provider's contractual data protection terms to keep the protection travelling with the data.
5. Who else can see your information
Circle is a shared record by design. Other members of a circle you belong to can see the entries, evidence and notes within that circle, and can see your name and profile photo. Consider that before uploading anything you would not want those people to read.
Outside that, we disclose personal data only where we are legally required to — for example in response to a valid order from a court or a regulator — or where it is necessary to investigate fraud or a serious breach of our terms.
6. How long we keep it
Ledger entries are append-only: the product exists to preserve a record, so entries and their attached evidence are retained for as long as the circle they belong to remains active, and for [CONFIRM retention period — e.g. seven years] afterwards where they may be needed as financial records.
Account information is kept while your account is open. If you close your account we delete your profile, though entries you contributed remain visible to the other members of that circle as part of its history, attributed to a removed user.
7. How we protect it
- All traffic between the application and our servers is encrypted in transit using TLS.
- Data is encrypted at rest by our infrastructure providers.
- Access to the ledger is restricted at the database level, so a member can only read the circles they belong to.
- Administrative access is limited to those who need it to operate the service.
No system is perfectly secure. If a breach occurs that is likely to put your rights at risk, we will notify you and the relevant authority without undue delay.
8. Your rights
Wherever you are, you may ask us to:
- give you a copy of the personal data we hold about you;
- correct anything that is inaccurate;
- delete your account and personal profile;
- export your data in a portable format;
- stop processing your data in certain circumstances.
Write to info@goshenlabs.tech, or to Goshen Labs Ltd, House No. 20, Donut Street, Community 25, Tema, Greater Accra, Ghana, and we will respond within 30 days.
If you are in Ghana and are unhappy with our response, you may complain to the Data Protection Commission of Ghana. If you are in the UK or EU, you may complain to your national supervisory authority.
9. Children
Circle is not intended for children and we do not knowingly collect personal data from anyone under 18. If you believe a child has given us their information, contact us and we will delete it.
10. Changes to this policy
If we change how we handle your data we will update this page and change the "last updated" date above. Where the change is significant we will tell you inside the application before it takes effect.