Privacy Policy

1Data controller and contact

Circlay is an iPhone app developed and published by Jorge Maldonado Borbón, operating under the IndieLob brand (hereinafter “the developer”, “we” or “us”).

• Data controller: Jorge Maldonado Borbón (IndieLob)
• App: Circlay, for iPhone
• Contact and privacy email: support@indielob.com

As explained below, the developer does not receive, host or have any way to view your contacts or anything you save in the app. Even so, you are welcome to write to us with any privacy question.

2Scope of this policy

This policy describes how data is handled by the Circlay app for iOS (iOS 18 or later) and its extensions — the widgets and the call blocking and identification extension — across all of its features, including the optional Circlay Pro purchase. It also covers this website’s support form (section 18).

It does not cover third-party services you may use alongside the app — mainly Apple (Contacts, iCloud, the App Store, Maps, speech recognition, Apple Intelligence, Calendar, Messages, Mail) and the apps or websites you open from Circlay (WhatsApp, Instagram, Google Maps, Waze, etc.) — which are governed by their own privacy policies.

3What Circlay does not do

To leave no room for doubt, here is the list of things the app does not do:

4Access to your contacts

Circlay is a different way of viewing your iPhone’s Contacts app, so its core function requires the Contacts permission that iOS asks you for. You can grant full access, limit it to certain contacts or revoke it in Settings › Apps › Circlay.

• What it reads: the data on the contact cards you give it access to (name, photo, phone numbers, email addresses, addresses, company and job title, birthday, social profiles and websites) in order to draw the circles, show contact details, search, detect duplicates and schedule birthday alerts.
• What it writes, only when you ask it to: new contacts (including those you scan from a business card or receive by QR code), the photo you choose for a contact, the merging of duplicate contacts and the deletion of contacts (including temporary contacts, which Circlay deletes on the date you choose).
• Changes made by Circlay are saved to your Contacts, so they sync with whatever account you have set up in iOS (iCloud, Google, Exchange…), just as if you had made them in the Contacts app.
• The developer never receives a copy of your contacts.

5What the app stores and where

In addition to what is already in Contacts, Circlay stores the app’s own information in the private, sandboxed space that iOS reserves for it on your iPhone (and in a container shared only with its own extensions). No other app, and not the developer, can access it.

If you back up your iPhone to iCloud or to your computer, this data is included in that backup, which is managed by Apple.

6Optional iPhone permissions

Apart from Contacts, all permissions are optional: iOS asks for them only when you use the feature that needs them, and you can revoke them in Settings › Apps › Circlay. The rest of the app keeps working without them.

• Microphone: only while you are recording a voice note. The audio is stored on your iPhone and is never sent to the developer.
• Speech recognition: to turn your voice notes into text. Circlay first requests transcription on the iPhone itself; if that is not available, iOS may send the audio to Apple’s servers for transcription, under Apple’s privacy policy.
• Location (only while using the app): to sort your contacts by distance on the map and guide you to an address. No history of your locations is kept, and nothing is sent to the developer.
• Camera: to read contact QR codes and photograph business cards. Images are analyzed on the iPhone and are not saved.
• Photos: Circlay uses the system photo picker, so it receives only the image you choose (for a contact’s photo, a background, or to read a card or a QR code); it has no access to the rest of your photo library.
• Calendar (full access): only if you turn on “Show in Calendar”. Circlay creates a calendar named “Circlay” with your pending reminders and your “Keep in Touch” dates. That calendar syncs with the calendar account you have set up in iOS. When you turn the option off, Circlay stops updating it.
• Notifications: for the reminders, birthdays and goals you set up. They are local notifications scheduled on the iPhone; they do not go through any server.
• Call blocking and identification: if you turn on the extension in Settings › Apps › Phone › Call Blocking & Identification, iOS reads the list of numbers you have added. Circlay cannot see who calls you or when.

To log in your history a call that you start from Circlay, the app uses the system API that only indicates whether an outgoing call has started; it does not access the dialed number by any other means, the call’s duration or its content.

7Apple services used by the app

• Maps and directions: to place your contacts on the map, Circlay sends the text of the address to Apple’s geocoding service; to calculate a route or show Look Around, it sends the origin and destination to Apple Maps. Apple handles those requests under its own privacy policy, and they are not associated with any developer account.
• Apple Intelligence: contact summaries and advanced business card reading use Apple’s model running on the iPhone itself. Your data is not sent to any server to generate them.
• Messages and Mail: when you write to someone or use a template, Circlay opens Apple’s sheet with the text already filled in. iOS does the sending with your account; Circlay only learns whether it was sent, in order to log it in your history.
• Phone and FaceTime: calls are made by iOS; Circlay plays no part in them.
• Crash reports: if you have turned on sharing analytics data with app developers in iOS, Apple may provide us with anonymous technical crash reports. You control this in Settings › Privacy & Security › Analytics & Improvements.

8Third-party apps you open from Circlay

When you tap a social network, a website or “Open in Google Maps / Waze”, Circlay opens that app or website, passing it only what is necessary (the username, the number, the link or the address). From that point on, whatever you do there is governed by that third party’s privacy policy. Circlay receives nothing back, other than logging in your local history that you opened that network.

9Sharing by QR code and exporting

• Contact QR code: the code contains a standard vCard with the fields you leave switched on (phone numbers, email addresses, addresses, social profiles, company, birthday) and, if you choose, the circle style and the “About This Contact” context. Anyone who scans the code can read that data, so check the switches before showing it. The QR code is generated on the iPhone, without going over the internet.
• Receiving a QR code: a preview is shown before anything is saved; you decide whether to save the contact and whether to import its style or its context.
• CSV/PDF export and backup file: these are created on your iPhone and saved or shared wherever you choose. From that moment on, they are in your custody.

10iCloud Drive backup

So that you don’t lose your information when you switch iPhones, Circlay can save a copy to your iCloud Drive, in the “Circlay” folder you see in the Files app.

• It is on by default and runs at most once every 12 hours when you leave the app. You can turn it off in System › Backup & Export.
• The file includes all of Circlay’s own data described in section 5 (including voice note audio) and a fingerprint of each contact (name, phone numbers and email addresses) used to recognize them when restoring on another iPhone. It does not include your Contacts, which iOS already syncs.
• It is stored in your private iCloud space, tied to your Apple Account. The developer cannot see, read or recover that file.
• If the iPhone is not signed in to iCloud or iCloud Drive is turned off, no backup is made and everything stays on the iPhone only.

The handling of data stored in iCloud is governed by Apple’s Privacy Policy and the iCloud terms.

11Purchases and free trial

Circlay Pro is a one-time purchase handled entirely by Apple, through the App Store and your Apple Account.

• The developer never sees or receives your payment method, your billing address or your Apple Account.
• To calculate the 7-day trial, the app asks Apple for the date of the first download and stores a copy in your iPhone’s keychain. That date never leaves the device.
• “Restore Purchases” simply asks Apple to check the purchases on your Apple Account again.
• Apple provides the developer with aggregated, anonymous sales reports that do not allow any buyer to be identified.

12Other people’s data

By its nature, Circlay stores information about other people: your contacts. That information is yours and you are the one handling it, for your own personal or professional use, on your iPhone. The developer does not act as a processor of that data because it never receives it.

We ask that you use notes, history, voice notes and the other features with respect for those people and in accordance with applicable law; for example, do not record anyone without their consent where the law requires it, and do not share third parties’ data by QR code without their permission.

13Children

Circlay is not directed at children and does not collect personal data from anyone, whatever their age. There are no public profiles, no in-app messaging, no content from other users and no targeted advertising.

14Your rights and your control

Laws such as the European GDPR, California’s CCPA/CPRA and Mexico’s LFPDPPP grant rights of access, rectification, erasure, objection and portability over the personal data a company holds about you.

If you have any privacy-related question, write to us at support@indielob.com and we will reply within a reasonable time.

15How to delete your data

• A history entry, a voice note, a reminder or a template: delete it from its screen within the app.
• Everything about a contact: deleting a contact from Circlay also removes its style, notes, history, voice notes, reminders, group, tags, goal, favorite and summary.
• All local data at once: uninstall the app. iOS deletes its data along with it (your Contacts are left untouched).
• The iCloud backup: delete the “Circlay” folder in Files › iCloud Drive, or manage your storage in Settings › [your name] › iCloud.
• The “Circlay” calendar: turn off “Show in Calendar” and delete the calendar from the Calendar app.

16Retention and security

• Your data is kept for as long as you want. The only exceptions are temporary contacts, which are deleted on the date you choose, and addresses that could not be found on the map, which are looked up again after 7 days. The history keeps at most the 5,000 most recent entries.
• Local data lives in the app’s sandboxed container and is protected by the iPhone’s encryption and by your passcode, Face ID or Touch ID.
• The backup travels encrypted to your iCloud Drive and is accessible only with your Apple Account.
• Since there are no developer servers or centralized databases, there is no store of information that could be leaked.

17App Store privacy labels

Consistent with all of the above, Circlay’s App Store listing is declared as “Data Not Collected”: the app does not send data to the developer or to third parties for their use, and it does not track you within the meaning of Apple’s App Tracking Transparency (which is why you will never see the tracking permission prompt).

18This website’s support form

If you write to us through the support form on circlay.indielob.com, we receive your name, email address, subject and message by email, for the sole purpose of replying to you. They are not stored in any database or used for advertising. To prevent abuse, the server keeps a hashed fingerprint of your IP address for one hour, after which it is deleted automatically. This website uses no cookies or analytics; the language selector only stores your choice in your own browser.

19Changes to this policy

If a new feature were ever to change how data is handled, we will update this policy and its “Effective date”. If the change is substantial, you will be notified within the app itself or in the App Store release notes.

20Language and precedence clause

The Spanish version of this Privacy Policy is the only official and legally binding version. The versions available in other languages — English, French, Italian, Brazilian Portuguese, European Portuguese, German, Turkish, Simplified Chinese and Dutch — are published solely for informational purposes and as a courtesy, to make it easier to understand, and have no legal force in themselves.

In the event of any discrepancy, contradiction, ambiguity, translation error or omission, or conflict of interpretation between the Spanish version and any of its translations, the Spanish version shall always prevail in its entirety and shall govern for all legal purposes.

21Contact

For any question, request or clarification about this Privacy Policy: