outercircl Cookie Policy
This Cookie Policy explains how outercircl Limited ('we', 'us', 'our') uses cookies and similar tracking technologies on the Services, in compliance with the Irish ePrivacy Regulations 2011 (S.I. No. 336 of 2011) and the General Data Protection Regulation (EU) 2016/679 ('GDPR'). It supplements, and should be read together with, our Privacy Policy and Terms & Conditions. Where this Cookie Policy conflicts with a more specific statement in the Privacy Policy about a particular cookie or technology, the more specific statement controls.
1. WHAT ARE COOKIES? A cookie is a small text file placed on your device when you visit a website or use an app, which allows us or a third party to recognise your device on return visits and store certain information about your preferences or activity. We use the term 'cookies' in this policy to also cover similar technologies, such as local storage, that serve the same purpose.
2. THE CHOICE YOU ARE ASKED FOR When you first visit the Services, you are shown a cookie banner offering a real, affirmative choice: 'Essential only' or 'Accept analytics'. Non-essential cookies are never placed before you make that choice, the choice is never bundled with your acceptance of our Terms & Conditions, and you can change your mind at any time from Settings or at the top of this page. Choosing 'Essential only' does not restrict your ability to use the Services \u2014 only strictly necessary cookies (see Section 3) will ever be placed regardless of your choice, as these do not require consent.
3. STRICTLY NECESSARY COOKIES (ALWAYS ON) These cookies are essential for the Services to function \u2014 such as keeping you signed in, remembering your session, and protecting the security of your account. Because they are essential to deliver the service you have requested, they do not require your consent and cannot be switched off through the cookie banner or Settings.
- Authentication and session cookies (Supabase Auth) \u2014 keep you signed in and your session secure.
- Basic security and anti-fraud cookies \u2014 help us detect and prevent abuse of the Services.
4. CURRENTLY ACTIVE NON-ESSENTIAL COOKIES \u2014 PRODUCT ANALYTICS The only non-essential cookie category active today is product analytics, provided by PostHog EU Cloud (hosted in Frankfurt, Germany). This is not advertising and does not involve cross-site tracking \u2014 it helps us understand how the Services are used so we can improve them.
- Placed only if you choose 'Accept analytics' in the cookie banner, or later opt in from Settings or at the top of this page.
- IP addresses are anonymised before storage and never retained in identifiable form.
- Analytics data is pseudonymised \u2014 linked to an internal user identifier, not directly to your name or email.
- We don't record sessions, and analytics never collects what you type or the words on the screen (such as other members' names) \u2014 only which pages are opened and which buttons are tapped.
- All analytics data is stored on EU servers subject to EU data protection law, under a Data Processing Agreement between outercircl and PostHog.
- You can withdraw this consent at any time from Settings or at the top of this page, signed in or not \u2014 withdrawing stops further collection immediately and removes the analytics identifier stored on your device.
5. RESERVED FOR FUTURE USE \u2014 SPONSORSHIP AND ADVERTISING COOKIES We do not currently run advertising or sponsorship placements on the Services, and no advertising, retargeting, or interest-based cookie is active today. We expect to introduce sponsored content and/or advertising in the future \u2014 for example, sponsor placements connected to events or Circls on the platform \u2014 which may involve third-party ad networks or retargeting platforms and their own cookies. Before any such cookie is placed on your device, we will:
- update this Cookie Policy and our cookie consent banner to name the specific provider(s) and purpose involved;
- obtain your prior, informed, affirmative consent before that cookie is placed \u2014 never assumed, never bundled with acceptance of our Terms, and never a condition of using the Services; and
- give you a way to withdraw that consent as easily as you gave it, at any time, from Settings or this page.
This section will be updated with the specific detail of any such cookies once they are introduced.
6. HOW TO MANAGE YOUR COOKIE CHOICES You can change your analytics consent at any time from Settings on the Services, or at the top of this page (no account needed). You can also control cookies at the browser level \u2014 most browsers let you view, delete, or block cookies through their settings \u2014 though blocking essential cookies may prevent you from using parts of the Services, including staying signed in.
7. THIRD-PARTY COOKIES Some cookies are placed by third parties who provide services to us, not by outercircl directly (for example, PostHog for analytics, as described in Section 4). We do not control these third parties' own cookie practices beyond the terms of our agreements with them. See our Privacy Policy, Section 4 ('When and With Whom Do We Share Your Personal Information'), for the categories of third-party service providers we work with.
8. CHANGES TO THIS COOKIE POLICY We may update this Cookie Policy from time to time, including when we introduce new cookies or technologies (such as the future sponsorship/advertising cookies described in Section 5). We will post the updated version here with a new 'Last updated' date, and where required by law will seek fresh consent before any new non-essential cookie is placed.
9. CONTACT US Questions about this Cookie Policy or your choices can be sent to [email protected].
This Cookie Policy is provided as a working draft alongside our Terms & Conditions and Privacy Policy. It should be reviewed and approved by a qualified solicitor familiar with Irish and EU data protection law before publication.