Children's Privacy & COPPA Compliance

About COPPA

The Children's Online Privacy Protection Act (COPPA) is a United States federal law that governs the collection of personal information from children under 13 years of age. COPPA requires operators of websites and online services directed to children to obtain verifiable parental consent before collecting personal information from children under 13.

Circle is operated by Circle LLC, a Virginia limited liability company. We take our COPPA obligations seriously and have designed our platform from the ground up with children's privacy as a core requirement — not an afterthought.

How Circle is designed for COPPA compliance

Circle uses a parent-controlled account model. Children do not create their own accounts and never interact with our registration or billing systems. Here is how the model works:

• Only adults 18 years of age or older may create a Circle account
• Child profiles are sub-accounts created entirely by the parent or guardian
• Children access Circle only through a parent-created profile, protected by a PIN set by the parent
• No personal information is collected directly from children — all information about a child (name, age, avatar) is entered by the parent
• Children cannot make purchases, send messages, or access any account settings

What information we collect about children

Circle collects the minimum information necessary to provide the service. For each child profile, we collect:

• First name — entered by the parent, used to personalize the child's viewing experience
• Age — entered by the parent, used to surface age-appropriate content
• Avatar — an emoji and color selected by the parent, used to identify the child's profile
• Daily screen time limit — set by the parent, enforced by the platform
• Hashed PIN — a one-way encrypted version of the child's PIN; the actual PIN digits are never stored
• Watch history — which videos were watched, when, and for how long; this data is visible to parents and used to enforce screen time limits

We do not collect from children:

• Last name, email address, phone number, or home address
• Precise geolocation
• Photos, videos, or audio recordings
• Behavioral or interest profiles for advertising purposes
• Social connections or contact lists
• Any information beyond what is listed above

Parental consent

Because children do not create accounts and all child profiles are created by verified adult account holders, Circle's design itself serves as the mechanism for parental consent. By creating a child profile, a parent or guardian is expressly consenting to Circle's collection and use of that child's limited profile information as described in this document and our Privacy Policy.

Parents may revoke consent at any time by deleting the child's profile from the account dashboard or by contacting us at hello@circletv.co.

How we use children's information

We use the information collected from child profiles solely to:

• Display the child's name and avatar on their viewing screen
• Surface age-appropriate content from subscribed creators
• Enforce the daily screen time limit set by the parent
• Authenticate the child's access via their PIN
• Track watch history so parents can see what their child has watched
• Automatically stop playback when the child reaches their screen time limit

We do not use children's information to:

• Serve targeted or behavioral advertising
• Build interest profiles or segment children for marketing purposes
• Share with third parties for commercial purposes
• Make automated decisions that have legal or similarly significant effects on children

Third-party services and children's data

Circle uses a limited number of trusted third-party service providers to operate the platform. The following providers may process children's data as part of delivering our service:

• Supabase — our database and authentication provider. Child profile data (name, age, avatar, watch history) is stored in Supabase's infrastructure. Supabase is SOC 2 compliant and processes data under a data processing agreement with Circle.
• Mux — our video hosting and streaming provider. Mux delivers video content to children's devices. Mux does not receive children's personal information; it receives only the video playback requests necessary to stream content.
• Vercel — our web hosting provider. Vercel hosts the Circle application and processes server requests. Children's personal data is not stored by Vercel.

We do not share children's information with advertisers, data brokers, analytics companies, or any other third parties beyond those listed above.

Parent and guardian rights

As the parent or guardian of a child with a Circle profile, you have the following rights at any time:

• Review — view all personal information associated with your child's profile by logging into your Circle account and visiting the family settings page, or by emailing hello@circletv.co to request a full data export
• Correct — update your child's name, age, or avatar at any time from the account settings
• Delete — permanently delete your child's profile and all associated data from the family settings page, or by emailing us. Deletion is irreversible and will remove all watch history, profile information, and session data.
• Restrict — limit what your child can watch by adjusting their screen time limit, changing their subscriptions, or removing their profile entirely
• Refuse further collection — delete your child's profile at any time to stop all data collection associated with that child

To exercise any of these rights, you may use the account dashboard directly or contact us at hello@circletv.co. We will respond to all requests within 30 days.

Data retention for child profiles

• Child profile data (name, age, avatar, PIN hash) is retained for as long as the profile exists in your account
• Watch history is retained for 12 months and then automatically deleted
• When a child profile is deleted, all associated data is permanently removed within 30 days
• When a parent account is closed, all child profiles and associated data are deleted within 30 days

Security measures for children's data

We apply the following security measures specifically to protect children's data:

• All data is transmitted over encrypted HTTPS/TLS connections
• Child PINs are hashed using bcrypt — the actual PIN digits are never stored or retrievable
• Row-level security on our database ensures that parent accounts can only access their own children's data
• Child viewing sessions are isolated — children cannot access parent account settings, billing, or marketplace features
• The child viewing interface has no external links, search functionality, or user-generated content

No advertising to children

Circle is completely ad-free. We do not display advertisements to children, collect data for advertising purposes, or share children's information with advertising networks. Creator subscriptions are the sole revenue model. Creators are paid directly from subscription fees — not from advertising revenue.

Content safety

All content available to children on Circle is reviewed and approved by Circle before it becomes available on the platform. Creators must agree to our content standards, which prohibit violence, adult themes, commercial messaging directed at children, and any content inappropriate for the age range of our platform (ages 3–12).

Circle does not host user-generated content that has not been reviewed. Children cannot upload, comment, or interact with other users in any way.

Contact our privacy team

If you have questions about how Circle handles your child's information, or if you wish to exercise any of your parental rights under COPPA, please contact us:

You may also file a complaint with the Federal Trade Commission (FTC) at ftc.gov if you believe your child's privacy rights have been violated.