This policy explains what information we collect when you use Pencircle’s sites, services, mobile applications, products, and content (“Services”). It also has information about how we store, use, transfer, and delete that information. Our aim is not just to comply with privacy law. It’s to earn your trust.
Information We Collect & How We Use It
Pencircle doesn’t make money from ads. So, we don’t collect data in order to advertise to you. The tracking we do at Pencircle is to make our product work as well as possible. This includes basic product functions like measuring readership and key features like personalizing what posts you see based on what we think you’ll like. So, to give you the best possible experience in using Pencircle, we collect information from your interactions with our Services. Some of this information, you actively tell us (such as your email address, which we use to track your account or communicate with you). Other information, we collect based on actions you take while using Pencircle, such as what pages you view (including how much of a given page and for how long) and your use of product features (like pseudonyms, bookmarks, follows, subscriptions and likes). This information includes records of those interactions, your Internet Protocol address, information about your device (such as device or browser type), and referral information (how you got to a particular page).
We use this information to:
- provide, test, improve, promote and personalize the Services
- fight spam and other forms of abuse
- generate aggregate, non-identifying information about how people use the Services
When you create your Pencircle account, and authenticate with a third-party service we may collect, store, and periodically update information associated with that third-party account, such as your lists of friends or followers. We will never publish something through one of your third-party accounts without your express permission.
Pencircle won’t transfer information about you to third parties for the purpose of providing or facilitating third-party advertising to you. We won’t sell information about you to a third-party.
We may transfer your account information with third parties in some circumstances, including: (1) with your consent; (2) to a service provider or partner who meets our data protection standards; (3) with academic or non-profit researchers, with aggregation, anonymization, or pseudonymization; (4) when we have a good faith belief it is required by law, such as pursuant to a subpoena or other legal process; (5) when we have a good faith belief that doing so will help prevent imminent harm to someone.
If we are going to share your information in response to legal process, we’ll give you notice so you can challenge it (for example by seeking court intervention), unless we’re prohibited by law or believe doing so may endanger others or cause illegal conduct. We will object to legal requests for information about users of our services that we believe are improper.
Search engines may index your Pencircle user profile page, public interactions, and post pages, such that people may find these pages when searching against your name on services like Google, DuckDuckGo, or Bing. Users may also share links to your content on social media platforms such as Facebook or Twitter.
Pencircle uses third-party vendors and hosting partners, such as Amazon, for hardware, software, networking, storage, and related technology we need to run Pencircle. We maintain two types of logs: server logs and event logs. By using the Services, you authorize Pencircle to transfer, store, and use your information in the countries where we operate.
Tracking & Cookies
We use browser cookies and similar technologies to recognize you when you return to our Services. We use them in various ways, for example to log you in, remember your preferences, evaluate email effectiveness, and personalize content and other services.
We track your interactions within the Pencircle Services (which encompasses pencircle.com, and your interactions with our mobile application).
Modifying or Deleting Your Personal Information
If you have a Pencircle account, you can access and modify your personal information, or delete your account.
To protect information from accidental or malicious destruction, we may maintain residual copies for a brief time period (generally several weeks). But, if you delete your account, your information and content will be unrecoverable after that time. Pencircle may preserve and maintain copies of your information beyond this time period when required to do so by law.
We use encryption (HTTPS/TLS) to protect data transmitted to and from our site. However, no data transmission over the Internet is 100% secure, so we can’t guarantee security. You use the Service at your own risk, and you’re responsible for taking reasonable measures to secure your account.
Email from Pencircle
Sometimes we’ll send you emails about your account, service changes or new policies. You can’t opt out of this type of “transactional” email (unless you delete your account).
When you interact with an email sent from Pencircle (such as opening an email or clicking on a particular link in an email), we may receive information about that interaction.
We won’t email you to ask for your password or other account information. If you receive such an email, please forward it to us at firstname.lastname@example.org so we can investigate.
Changes to this Policy
Pencircle may periodically update this Policy. We’ll notify you about significant changes to it. The most current version of the policy will always be here .
We welcome feedback about this policy at email@example.com.
Data Protection Statement for European Union Users
Description of Processing Activity
Pencircle collects and stores personal information about its users to customize their reading experience and enable personalized distribution of content. It shares minimal data with its service providers.
Purposes of Processing
- Provide, test, promote, and improve the Services
- Gather usage statistics of services
- Provide customized reading experience
- Publish and distribute user-generated content Fight spam, fraud, and other abuse of services
In order to provide the Services, Pencircle collects and stores personal data about its users to fulfil its contractual obligations to users as described in our Terms of Service.
Pencircle also pursues its legitimate interests by collecting minimal data of logged out users to provide the Services, as outlined above. These legitimate interests are not outweighed by (nor do they violate) our users’ privacy interests because we collect minimal user data for these purposes, and we are fully transparent about these activities.
Pencircle will consider related complaints in compliance with the General Data Protection Regulation’s rights of the data subject, as well as rights of expression and access to information.
Public Nature of Personal Data
Logged-in users may choose to interact publicly with the Services in the form of liking a post, following other user accounts, subscribing to zines, sharing links on connected social media accounts, or writing original posts. Where such personal data may reveal special category protected data, it is processed on the basis that it is manifestly made public by the user. Additional information on potential consequences of such processing can be found below. If you do not agree to this public usage, do not create an account or use these features of the Services.
Search engines may index your Pencircle user profile page, public interactions, and post pages. Users may also share links to your content on social media platforms such as Facebook or Twitter.
Categories of Personal Data Collected
Logged out users:
- Reading history
- IP address
- Browser information
- DNT status
Logged in users:
- Display name
- Profile description
- Profile image
- Profile cover image
- Email address (non-public)
- Session activity (security)
- Linked social media accounts (optional)
- IP address
- Browser information
- Reading history (on Pencircle Services only)
- Network interactions (likes, follows, etc.)
- Posts published by user
Categories of Recipients
Pencircle shares minimal personal data with third-party processors in order to provide the Services. These processors offer at least the same level of data protection as that set out in this statement. This includes the following categories of recipients:
- Hosting, Storage, & Other Infrastructure
- Communication & Support
Use of Algorithms to Personalize User Experience
Pencircle collects and stores personal data about its users to customize their reading experience by displaying content tailored to the preferences and interests indicated by the users (including through their reading history and Services interactions). This does not constitute automated decision-making as that phrase is used in the GDPR because it does not produce any legal effects or similarly significant effects for users. Pencircle also moderates content for the purposes of fighting and preventing spam, fraud, and other forms of abuse, and may rely on algorithms as part of doing so.
Potential Consequences of Processing
By creating and using an account on Pencircle, users may make certain personal data about themselves public and accessible to others on their profile and through network interactions. This may in some cases constitute special category protected data which is considered manifestly made public by the user.
Due to the public nature of information posted to Pencircle, it may be possible for third parties to derive identifying personal data from posts, whether by reading, inference, supplemental research, or automated extraction and analysis.
Users are free to use their real name and information, or a pseudonym of their choosing, for their account. Users may also choose to use the service without posting data or engaging in network interactions. However, if you do not agree with and accept the risks of such usage, you may not use the Services.
Pencircle retains personal data associated with your account for the lifetime of your account. If you would like to delete your personal information, you can delete your account at any time. Deleted account profile pages will yield an error 404 “file not found” page, immediately upon initiating deletion, and will become unrecoverable in our system after a period of fourteen days. It may take several additional days for your personal data to be de-indexed from search engines, depending on those search engines’ practices, over which Pencircle may have limited or no control.
Rights of Data Subjects
- You may correct information associated with your account from the Edit Profile page.
- You may withdraw consent by deleting your account at any time through the Profile View page, which will erase your personal information completely within 14 days (except to the extent Pencircle is prevented by law from deleting your information).
- You may object at any time to the use of your personal data by contacting firstname.lastname@example.org. If your complaint relates to alleged misuse of your personal data by a third party, it may result in suspension of that post or account in keeping with relevant law, public interest, our contractual obligations, and the rights of expression and access to information of others.
- Under EU law you have the right to lodge a complaint regarding the processing of your personal data by Pencircle with the dedicated Supervisory Authority of your EU member state.
Subject Access Requests
For security and account ownership verification reasons, we process Subject Access Requests and account deletion requests from the account holder only. We are unable to process requests made by third-party services.
These requests can be made at email@example.com.