Circle VPN — Terms & Conditions & Privacy Policy
Last Updated: 05 September 2025
Welcome to Circle VPN, provided by Second Team (Ontario, Canada) (“we,” “us,” or “our”). By downloading, installing, or using Circle VPN (the “App”), you agree to these Terms and this Privacy Policy. If you do not agree, please uninstall the App and discontinue use.
For questions, contact privacy@circlevpn.net. For data deletion requests, contact info@circlevpn.net (see Section 5.9).
1) Description of Service
Service. Circle VPN is a Virtual Private Network (VPN) application that uses the V2Ray protocol to provide secure, encrypted connections to servers around the world. The service aims to enhance your privacy online, protect your data on public Wi‑Fi.
Free of charge. The App is free to download and use. We generate revenue through third‑party advertising (e.g., Google AdMob).
No account required. You do not need to create an account to use the App.
No VPN activity logs. We do not monitor, record, or store VPN traffic content, browsing activity, DNS queries, or VPN connection timestamps on our VPN servers. (See Section 5.3 for other technical data processed to operate the App.)
Third‑party services. We integrate external services for ads, analytics, crash reporting, and hosting. See Section 6.
2) License to Use the App
We grant you a personal, non‑exclusive, non‑transferable, revocable, limited license to install and use Circle VPN on your Android device for lawful purposes. You may not distribute, sell, sublicense, modify, reverse engineer, or create derivative works of the App, except where permitted by applicable open‑source licenses (see Section 4).
3) User Responsibilities & Acceptable Use
By using the App, you agree to:
Use the App only for lawful purposes.
Not engage in illegal activities (e.g., hacking, fraud, distribution of malware, child exploitation, or copyright infringement).
Not misuse our network or servers (e.g., DoS attacks, spamming, or network abuse).
Not resell or commercially exploit the free service.
You must comply with the policies of your ISP, employer, school, or venue network.
You are responsible for ensuring VPN use is legal in your location.
Violation of these rules may result in suspension or termination of access and, where required, reporting to law enforcement.
4) Intellectual Property
All rights to Circle VPN, including software, design, logos, and trademarks, belong to Second Team. You may not copy, distribute, or use our branding without written permission. Open‑source components (e.g., V2Ray) are used under their respective licenses.
5) Privacy Policy & Data Usage
We take your privacy seriously and design Circle VPN to minimize personal data collection.
Controller: Second Team (Ontario, Canada). Contact: privacy@circlevpn.net (general) and info@circlevpn.net (rights & deletion).
5.1 Data We Do Not Log on VPN Servers
Browsing/content of traffic
DNS queries
User‑source IP addresses persistently (transient processing may occur to route traffic; see 5.3)
VPN connection timestamps persistently (transient processing may occur for performance and abuse prevention)
5.2 Data We May Collect (App)
To operate and improve the App, we process limited technical data:
Device model and OS version
App version and basic event/interaction telemetry (e.g., feature usage, session start/stop)
Resettable identifiers (e.g., Android Advertising ID (AAID), app instance ID)
Crash reports and performance diagnostics
Approximate location (city/region) for ad delivery, derived from coarse signals
Consent status and privacy choices (e.g., ad personalization opt‑in/opt‑out)
Note: Some third‑party providers may temporarily process IP addresses to deliver the service (e.g., routing, security, fraud prevention). We do not store these IPs ourselves.
5.3 Legal Bases (GDPR/EEA)
Consent – for personalized advertising and, where required, analytics.
Legitimate interests – to ensure app security, measure performance, and fix crashes.
Contractual necessity – to route VPN traffic and provide the core service.
5.4 Children’s Privacy
The App is not directed to children under 16 in the EU/EEA. Member‑state age thresholds may vary (13–16).
The App is not directed to children under 13 in the United States (COPPA). We do not knowingly collect personal information from children under 13. If you believe a child provided personal data, contact info@circlevpn.net and we will delete it.
5.5 Data Retention
We retain app telemetry and crash diagnostics only for as long as necessary to achieve the purposes described above, after which it is deleted or anonymized. Our third‑party providers apply their own retention schedules.
We do not keep permanent VPN traffic logs.
5.6 Sharing with Third Parties (Processors)
We use trusted service providers to operate the App and our website:
Google AdMob – advertising (personalized or non‑personalized depending on region/consent)
Google Firebase – analytics & crash reporting
Sentry – error monitoring
AWS and Laravel Cloud – hosting/back‑end services
Website services (if applicable): Microsoft Clarity and Nightwatch for website interaction/performance analytics (website only, not inside the App)
Each provider processes data under its own privacy terms and data processing agreements. We contractually require appropriate safeguards.
5.7 International Data Transfers
Data may be processed in Canada, the United States, and other regions. Where required, we rely on appropriate safeguards (such as Standard Contractual Clauses) to protect your data.
5.8 Your Privacy Rights
Depending on your location, you may have the right to access, correct, delete, restrict or object to processing, withdraw consent, or receive a copy of certain information. See Sections 5.10–5.11 for region‑specific rights.
How to exercise rights: Email info@circlevpn.net (preferred for deletion) or privacy@circlevpn.net. We may request information to verify your identity. We will respond within the timeframes required by law.
5.9 Data Deletion Requests (All Regions)
You may request deletion of personal data we control by emailing info@circlevpn.net with the subject line “Data Deletion Request – Circle VPN.”
We will delete/erase the information we control and instruct our processors to do the same where applicable, subject to legal obligations (e.g., fraud prevention, security, tax/accounting records) and technical limitations (e.g., data already aggregated or anonymized).
If your request relates to advertising preferences, you can also adjust your choices in the App (see 5.12) or through your device settings (reset AAID / disable ad personalization).
5.10 California & U.S. State Privacy Disclosures
This section applies to residents of California and other U.S. states with privacy laws (e.g., Virginia, Colorado, Connecticut, Utah). It also serves as our Notice at Collection for California.
Categories collected: identifiers (e.g., Android Advertising ID), internet/electronic activity (app interactions, telemetry), approximate geolocation (city/region), and diagnostics (crash/performance data).
Purposes: provide and secure the service, measure performance, fix crashes, and deliver advertising (personalized or non‑personalized depending on region/consent).
Disclosures: we disclose information to service providers that help us operate the App (e.g., AdMob, Firebase, Sentry, hosting). Our use of advertising identifiers for cross‑context behavioral advertising may be considered a “sale” or “sharing” under some state laws.
Your rights: right to know/access, delete, correct, opt‑out of sale/sharing and targeted advertising, and (where applicable) appeal a decision.
How to exercise rights: email info@circlevpn.net with your request and your state of residence. To opt‑out of sale/sharing or targeted advertising, use in‑app The Icon is Top-Right on app (see 5.12) or email us.
Appeals: if we deny your request, you may appeal by replying to our decision email with “Appeal.” We will review and respond within 45 days (or the timeframe required by law).
Non‑discrimination: we will not discriminate against you for exercising your rights.
Financial incentives: none.
5.11 GDPR/EEA Rights Summary GDPR/EEA Rights Summary
EEA/UK users have the rights to access, rectification, erasure, portability, restriction, objection, and to withdraw consent. You may also lodge a complaint with your local data protection authority. Contact info@circlevpn.net to exercise your rights.
EU/UK Representative (if applicable): If we become required to appoint a representative under GDPR Article 27, we will update this section with contact details.
5.12 Ads Consent & Privacy Choices (In‑App)
EU/EEA/UK: We obtain consent (e.g., via a consent dialog) for personalized ads. You can change your choice at any time in The icon is top-right on app .
U.S. states with privacy laws: You can opt‑out of targeted advertising (“sale”/“sharing”) via The icon is top-right on app, or by emailing us.
Device settings: You can reset the Android Advertising ID and/or disable ad personalization in your device settings.
5.13 Security
We use technical and organizational measures to protect information, including encryption in transit, restricted access, and monitoring. No method of transmission or storage is 100% secure.
6) Third‑Party Terms
By using the App, you also agree to the privacy terms of our service providers as applicable (e.g., Google AdMob, Firebase, Sentry, hosting providers). These providers act as processors or independent controllers for their respective services.
7) Disclaimers of Warranty
Circle VPN is provided “AS IS” and “AS AVAILABLE.” We do not guarantee uptime, speed, or access to specific websites. While we use encryption, no method of transmission is 100% secure.
8) Limitation of Liability
To the maximum extent permitted by law, in no event will Second Team’s aggregate liability arising out of or relating to the App exceed the greater of CAD $0 or the total amount you paid to us (if any) in the twelve (12) months preceding the event giving rise to the claim (for this free App, typically CAD $0). Nothing in these Terms limits or excludes liability for fraud, willful misconduct, gross negligence, or death or personal injury caused by negligence, or any other liability that cannot be limited by law. Your statutory rights are not affected.
9) Indemnification
You agree to indemnify and hold harmless Second Team from claims arising from your misuse of the App or violation of these Terms.
10) Termination
We may suspend or terminate your access if you violate these Terms or as needed for security or operational reasons.
11) Changes to This Policy
We may update these Terms & Privacy Policy from time to time. Material changes will be posted at https://circlevpn.netand/or in the App. The Last Updated date will reflect the effective date of the changes.
12) Governing Law & Dispute Resolution
These Terms are governed by the laws of Ontario, Canada, subject to mandatory consumer protections in your country of residence (including GDPR rights in the EU/EEA).
13) Severability
If any part of this document is found invalid, the remaining sections remain enforceable.
14) Entire Agreement
These Terms & Privacy Policy constitute the entire agreement between you and Second Team regarding Circle VPN.
15) Contact
Second Team
Ontario, Canada
Privacy/General: privacy@circlevpn.net
Data Deletion & Rights Requests: info@circlevpn.net
Website: https://circlevpn.net