Privacy Policy

Last updated: August 24, 2026

Personal Data Protection

CIRCLES HOUSE informs users of its website www.circles.house, its customer relationship management platform (“CRM”), and its related digital services and integrations about the processing and protection of personal data that may be collected through the use of these services.

This Privacy Policy applies to personal data processed through our website, CRM, communications systems, booking and customer management processes, and integrations with third-party platforms, including the WhatsApp Business Platform and Meta APIs.

CIRCLES HOUSE adopts the necessary technical and organizational measures to ensure the security, integrity, and confidentiality of personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR”), Organic Law 3/2018 of December 5 on the Protection of Personal Data and guarantee of digital rights, Law 34/2002 of July 11 on Information Society Services and Electronic Commerce, and other applicable data protection legislation.

Personal data may be collected when users interact with our website, submit forms, communicate with us by email, telephone, WhatsApp or other authorized channels, contract our services, make inquiries or reservations, or otherwise interact with our CRM and related services.

Person Responsible for the Processing of Personal Data

The person responsible for the processing of personal data is:

CIRCLES SL
NIF/CIF: B05377072
Registered office: Paseo Bonanova 26, 5º 2º, 08022 Barcelona, Spain
Registered in the Commercial Registry of Barcelona, Volume 47839, Folio 191, Page B563561, Inscription 1
Telephone: +34 619 432 469
Email: live@circles.house

CIRCLES HOUSE undertakes to apply appropriate security measures designed to prevent unauthorized access, misuse, alteration, deterioration, disclosure, or loss of personal data.

Information We Process

Depending on the way users interact with CIRCLES HOUSE, we may process the following categories of personal data:

Name and surname
Email address
Telephone number
Contact information
Identification and account information
Reservation and accommodation information
Customer preferences and inquiries
CRM records
Communications and conversation history
Information provided through website forms
Information exchanged through email, telephone, WhatsApp, or other communication channels
Technical information necessary to operate our digital services
Other information voluntarily provided by users

CRM and Customer Management Data

CIRCLES HOUSE uses a CRM and related technology systems to manage customer relationships, inquiries, reservations, communications, and internal operational workflows.

Information processed through the CRM may include:

Customer and contact profiles
Names, telephone numbers, and email addresses
Reservation or accommodation information
Customer inquiries and requests
Notes and internal customer management information
Communication history
Opportunities and other customer relationship records
Tasks and operational information related to customer service

Access to this information is limited to authorized users and service providers who require access to perform the corresponding business or technical functions.

WhatsApp Business and Meta Data

CIRCLES HOUSE may use the WhatsApp Business Platform and Meta APIs to communicate with customers and manage WhatsApp conversations through its CRM and related systems.

When users communicate with CIRCLES HOUSE through WhatsApp, or when WhatsApp Business is integrated with our CRM, we may process information made available through WhatsApp and Meta, including:

Telephone numbers
WhatsApp profile information made available to us
Incoming and outgoing messages
Message content
Message timestamps
Message delivery, read, and status information
Communication history
WhatsApp Business Account identifiers
Phone Number IDs
Business profile information
Message template information
Webhook events and other technical information required to operate the integration

This information is processed for the purpose of communicating with customers, managing customer inquiries and reservations, maintaining communication history within the CRM, providing customer service, and operating our business processes.

CIRCLES HOUSE does not use WhatsApp conversations for unrelated advertising purposes.

The use of WhatsApp and Meta services is also subject to the terms, privacy policies, and data processing practices established independently by Meta Platforms and WhatsApp.

Purposes of Data Processing

CIRCLES HOUSE may process personal data for the following purposes:

Managing inquiries and requests received from users
Managing reservations and accommodation-related services
Managing customer relationships through our CRM
Communicating with current and potential customers
Sending and receiving WhatsApp Business messages
Synchronizing communications with customer CRM records
Maintaining communication history
Providing customer support
Managing contractual and commercial relationships
Processing information requested through the website
Managing administrative and operational processes
Authenticating authorized users of our systems
Protecting our systems and preventing misuse
Troubleshooting technical problems
Improving the functionality, security, and reliability of our services
Complying with applicable legal and regulatory obligations
Sending commercial communications when legally permitted or when the user has provided the corresponding consent

Where required, users may object to commercial communications at any time by contacting live@circles.house or using any unsubscribe mechanism included in the relevant communication.

Legal Basis for Data Processing

Personal data may be processed on one or more of the following legal bases:

Performance of a Contract

Processing may be necessary to provide accommodation, reservation, customer service, or other services requested or contracted by the user.

Legitimate Interests

CIRCLES HOUSE may process data when necessary for legitimate business purposes, including customer relationship management, providing customer support, maintaining the security of our systems, and improving our services, provided that such interests do not override the fundamental rights and freedoms of the data subject.

Consent

Where required, processing may be based on the user's free, specific, informed, and unequivocal consent.

Users may withdraw consent at any time without affecting the lawfulness of processing performed before withdrawal.

Legal Obligations

Certain information may be processed or retained when required to comply with applicable legal, fiscal, administrative, regulatory, or judicial obligations.

Communications

Communications with users may be incorporated into CIRCLES HOUSE information systems and CRM when necessary to manage the corresponding customer relationship.

Official means of communication may include:

Corporate email
Corporate telephone numbers
WhatsApp Business
Website forms
Other communication systems expressly enabled by CIRCLES HOUSE

Where users have consented to receive commercial electronic communications, CIRCLES HOUSE may send information concerning services, promotions, news, offers, and other information related to its activities.

Users may withdraw their consent or object to receiving marketing communications at any time.

Service Providers and Recipients of Data

CIRCLES HOUSE does not sell personal data.

Personal data may be made available to third parties when necessary to provide our services or operate our technology infrastructure.

These recipients may include:

Hosting and infrastructure providers
Database and cloud service providers
CRM and software development providers
IT support and security providers
Communication service providers
Meta Platforms and WhatsApp when WhatsApp Business functionality is used
Booking, payment, or operational platforms where applicable
Professional advisers where necessary
Public authorities, courts, law enforcement agencies, or other entities where disclosure is required by law

Third-party technology providers acting on behalf of CIRCLES HOUSE may process information only to the extent necessary to provide their services and in accordance with applicable contractual and data protection obligations.

Where required, appropriate data processing agreements are maintained with service providers processing personal data on behalf of CIRCLES HOUSE.

International Data Transfers

Some technology and communication providers used by CIRCLES HOUSE, including global cloud and communications platforms, may process personal data outside Spain or the European Economic Area.

Where personal data is transferred internationally, CIRCLES HOUSE will use appropriate safeguards where required by applicable data protection law, which may include adequacy decisions, Standard Contractual Clauses approved by the European Commission, or other legally recognized transfer mechanisms.

Duration of Data Storage

CIRCLES HOUSE will retain personal data only for as long as necessary for the purposes for which it was collected and for the duration of the corresponding contractual or customer relationship.

Following termination of the relationship, certain information may be retained, duly restricted or blocked where appropriate, for the periods necessary to comply with applicable legal, contractual, administrative, or judicial obligations.

Where applicable, information may be retained for a period of up to 5 years after the end of the relevant business relationship, unless another retention period is required by applicable law.

CRM and communication data that is no longer required may be deleted or anonymized in accordance with our internal retention procedures.

Data Security

CIRCLES HOUSE uses reasonable technical, organizational, and administrative safeguards designed to protect personal data against unauthorized access, alteration, disclosure, misuse, loss, or destruction.

Access to CRM records, communications, and customer information is restricted to authorized users and systems that require such access for legitimate operational purposes.

However, no electronic transmission or storage system can be guaranteed to be completely secure.

Data Deletion Requests

Users may request the deletion of personal information held by CIRCLES HOUSE where they are legally entitled to do so.

Requests may be submitted to:

live@circles.house

Please include sufficient information to allow us to identify the relevant records, such as:

Your name
Your email address or telephone number
A description of the information you would like deleted

CIRCLES HOUSE may request additional information where necessary to verify the identity of the person making the request.

Once verified, eligible personal information will be deleted or anonymized within a reasonable period, except where retention is necessary to comply with legal obligations, establish or defend legal claims, prevent fraud or abuse, maintain security, or comply with other lawful retention requirements.

Rights of Concerned Individuals

Users may exercise the rights provided by applicable data protection legislation by contacting CIRCLES HOUSE at live@circles.house.

Requests should include sufficient information to identify the requesting person and the right they wish to exercise.

Depending on the circumstances, users may have the following rights:

Right of Access

The right to obtain confirmation as to whether personal data is being processed and to receive information about that processing.

Right to Rectification

The right to request correction of inaccurate or incomplete personal data.

Right to Erasure

The right to request deletion of personal data where the legal requirements for deletion are met.

Right to Object

The right to object to certain processing of personal data, including certain forms of direct marketing.

Right to Restriction of Processing

The right to request that processing of personal data be restricted in circumstances established by applicable law.

Right to Data Portability

Where applicable, the right to receive certain personal data in a structured, commonly used, machine-readable format and to transmit that data to another controller.

Right to Withdraw Consent

Where processing is based on consent, users may withdraw their consent at any time without affecting the legality of processing performed before withdrawal.

Rights Related to Automated Decision-Making

Where applicable, users have the right not to be subject to a decision based solely on automated processing, including profiling, where such decision produces legal effects or similarly significantly affects them, subject to the exceptions established by applicable law.

Users also have the right to lodge a complaint with the competent supervisory authority.

In Spain, the relevant supervisory authority is the Agencia Española de Protección de Datos (AEPD).

Third-Party Platforms and Services

Our website and CRM may integrate with or rely on third-party services.

These third-party services maintain their own privacy policies, terms, and data processing practices. CIRCLES HOUSE is not responsible for processing independently performed by such third parties outside CIRCLES HOUSE's control.

This includes services operated by Meta Platforms and WhatsApp.

Children's Privacy

Our services are not intended for children acting independently as customers.

CIRCLES HOUSE does not knowingly collect personal data from children through its website or CRM except where such processing is legally permitted and necessary in connection with accommodation services or other legitimate purposes and, where required, under the responsibility or authorization of a parent or legal guardian.

Changes to Our Privacy Policy

CIRCLES HOUSE may update this Privacy Policy from time to time to reflect changes in our services, technology, legal obligations, or data processing practices.

The updated version will be published on this page and will indicate the date of the latest revision.

Contact Us

If you have any questions regarding this Privacy Policy or the processing of your personal data, you can contact us:

CIRCLES SL / Circles House
Paseo Bonanova 26, 5º 2º
08022 Barcelona, Spain

Email: live@circles.house
Telephone: +34 619 432 469
Website: https://www.circles.house