Privacy Policy

We have appointed a Data Protection Officer (DPO), who is responsible for overseeing this privacy notice.

📧 vj@fittercircle.com

Our services are not intended for anyone under 18. If we identify users under 18, we delete their personal data.

We may collect the following personal data:

• Referrals data: Confirmation emails sent when a referral signs up or completes their first purchase/cash out. Emails sent to referrers may include the referee's first name and username.
• Registration data: Name, mobile number, email, device ID, OS, app version, login activity, referral tracking.
• Biometric data: Fingerprint/face recognition login (via your device). We do not store biometric data. PIN login is available as an alternative.
• Purchase/reward data: Company, amount, rewards earned, payment method, time of purchase, bonuses, voucher or gift card access.
• Payment data: If using Apple/Google Pay or Open Banking, details are processed by regulated third-party providers (we supply only necessary order details).
• Behavioural/personalisation data: We may analyse transaction and device data to provide tailored rewards.
• ID verification data: In some cases, we may request photo ID/video for KYC or use our partner (e.g., Sumsub).
• Cash out data: Bank account name, sort code, account number (stored to simplify future cash outs).
• Refund data: Processed via your original payment method.
• Marketing data: If opted in, you may receive emails, SMS or push notifications. You can opt out at any time.
• General communication data: When contacting us (e.g., email, chat, social media).
• Surveys data: Anonymised data for feedback purposes.
• Operational data: Device type, OS, crash logs, app version, session data.
• App data: Camera and location permissions (for loyalty card scanning, local offers).
• Cookies/analytics: We use tools such as Firebase, Crashlytics and Google Analytics.

We rely on the following legal grounds:

• Consent – e.g., marketing communications.
• Performance of a contract – to provide the service.
• Legal obligations – e.g., financial reporting, anti-money laundering.
• Legitimate interests – e.g., fraud prevention, improving services.

We may use automated profiling for fraud prevention or to personalise offers. You can request human review.

We may share data with:

• Open Banking providers
• Fraud prevention/KYC providers
• Digital payment providers
• Cloud hosting providers
• Analytics providers
• Customer service platforms
• Communication providers
• Social media (if you interact with us there)

Where personal data is transferred outside the UK/EU, we use appropriate safeguards (e.g., Standard Contractual Clauses + UK Addendum).

We are not responsible for privacy practices of third-party websites/apps linked from ours.

We retain data for as long as necessary for service delivery and compliance. Examples:

• AML records: 5 years after account closure/transaction.
• Claims defence: up to 6 years.
• Marketing data: until you withdraw consent.
• Cookies: see our cookie policy.

You may delete your account within the app, but this does not automatically erase personal data. To request erasure, contact vj@fittercircle.com.

You have the following rights:

• Access – see your data.
• Rectification – correct inaccurate data.
• Erasure – request deletion.
• Restrict/objection – stop/restrict processing.
• Portability – transfer your data.
• Withdraw consent – for consent-based processing.

Complaints: Contact us at vj@fittercircle.com or the ICO at ico.org.uk/concerns.