General Terms and Conditions

1. Introduction

1.1 These General Terms and Conditions ("Terms") govern the use of the Cirkly AB platform (the "Platform") by users ("Users").

1.2 By accessing or using the Platform, Users agree to be bound by these Terms. If Users do not agree to these Terms, they should not access or use the Platform.

1.3 User Acceptance: User acceptance of these Terms is evidenced by signing up for the service and joining or initiating a ROSCA.

2. Services

2.1 Cirkly AB provides an online platform that facilitates the administration and management of Rotating Savings and Credit Associations (ROSCAs).

2.2 The Platform may include features such as:

• Tracking contributions and disbursements.
• Managing member information.
• Facilitating communication between members.
• Generating reports and summaries.
• Providing payment notices and reminders.

2.3 Cirkly AB does not provide any financial services, such as holding funds or facilitating transfers. Users are solely responsible for managing all financial transactions related to their ROSCA.

3. Fees

3.1 The use of the Platform may be subject to fees.

• A separate fee schedule will be published and may be adjusted for each ROSCA.
• Users will be informed of any applicable fees for each ROSCA.

4. Data Privacy

4.1 The handling of User data is governed by Cirkly AB's separate Data Protection Notice, which can be accessed [insert link to Data Protection Notice].

5. Intellectual Property

5.1 The Platform and all its features are the exclusive property of Cirkly AB and are protected by intellectual property rights.

5.2 Users may not use the Platform for any illegal or immoral activities, including money laundering.

6. Liability

6.1 Cirkly AB's liability for any damages arising from the use of the Platform is limited to the value of the fees charged by Cirkly AB to the individual User.

7. Dispute Resolution

7.1 Disputes arising from or relating to these Terms or the use of the Platform shall be resolved through mediation in accordance with Swedish law.

8. Termination

8.1 Cirkly AB reserves the right to terminate a User's account or suspend access to the Platform at its discretion.

9. Governing Law

9.1 These Terms shall be governed by and construed in accordance with the laws of Sweden.

10. Changes to Terms

10.1 Cirkly AB reserves the right to modify these Terms at any time.

• Users will be notified of any changes through the Platform or by other reasonable means.
• Continued use of the Platform after the effective date of any changes constitutes acceptance of such changes.

DATA PROTECTION NOTICE

Introduction

This data protection notice explains how Cirkly AB collects, uses, and protects your personal data when you use our services. We are committed to protecting your privacy and ensuring that your personal data is handled in accordance with applicable data protection laws.

What personal data do we collect?

We may collect the following personal data from you:

• Identity data: Your name, date of birth, address, email address, phone number, and other contact details.
• Financial data: Your bank account details, payment information, and other financial information.
• Transaction data: Details about your savings goals, contributions, and withdrawals.
• Technical data: Your IP address, device information, and other technical data.
• Usage data: How you use our services, including the features you use and the pages you visit.
• Marketing and communications data: Your preferences for receiving marketing communications from us.

How do we collect your personal data?

We collect your personal data in the following ways:

• Directly from you: When you create an account, make a contribution, or contact us.
• Indirectly from you: When you use our services, we may automatically collect technical data and usage data.
• From third parties: We may receive personal data about you from third parties, such as credit reference agencies or fraud prevention agencies.

How do we use your personal data?

We use your personal data for the following purposes:

• To provide and improve our services: To create and manage your account, process your contributions and withdrawals, and provide customer support.
• To communicate with you: To send you updates about your savings goals, important notices, and marketing communications.
• To comply with legal obligations: To comply with anti-money laundering and other legal requirements.
• To protect our legitimate interests: To prevent fraud and abuse, and to enforce our terms and conditions.

Who do we share your personal data with?

We may share your personal data with the following third parties:

• Our service providers: We may share your personal data with our service providers who help us to provide our services, such as payment processors and IT providers.
• Legal and regulatory authorities: We may share your personal data with legal and regulatory authorities if we are required to do so by law.
• Other third parties: We may share your personal data with other third parties, such as credit reference agencies or fraud prevention agencies.

How do we protect your personal data?

We take appropriate technical and organizational measures to protect your personal data from unauthorized access, use, or disclosure. These measures include:

• Encryption: We use encryption to protect your personal data when it is transmitted over the internet.
• Access controls: We restrict access to your personal data to authorized personnel only.
• Data retention: We retain your personal data only for as long as necessary for the purposes for which it was collected.

Your rights

You have the following rights in relation to your personal data:

• Right of access: You have the right to request access to your personal data.
• Right to rectification: You have the right to request that your personal data be corrected if it is inaccurate or incomplete.
• Right to erasure: You have the right to request that your personal data be deleted in certain circumstances.
• Right to restriction of processing: You have the right to request that the processing of your personal data be restricted in certain circumstances.
• Right to data portability: You have the right to request that your personal data be transferred to another organization in certain circumstances.
• Right to object: You have the right to object to the processing of your personal data in certain circumstances.

Contact us

If you have any questions about this data protection notice or our privacy practices, please contact us at:

info@cirkly.se

Changes to this data protection notice

We may update this data protection notice from time to time. We will post any changes on our website and notify you by email if the changes are significant.

Effective date: 1 January 2025