Encircled Privacy Policy

Last Updated: January 13, 2026

This Privacy Policy applies to encircled.org (the “Site”) and any related pages, forms, services, or features that link to this Privacy Policy (collectively, the “Services”). The Services are owned and operated by Encircled (“Encircled,” “we,” “us,” or “our”).

This Privacy Policy explains how we collect, use, share, and protect information when you access or use our Services, including when you initiate or participate in a mentor circle plan, submit forms related to Encircled activities, or subscribe to our communications.

Please read this Privacy Policy carefully. By accessing or using the Services, you agree to the collection, use, and sharing of information as described here. If you do not agree, please do not use the Services.

1) Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, Services, or legal requirements. When we do, we will update the “Last Updated” date at the top and post the revised policy on the Site. Unless required by law, changes apply when posted and do not apply retroactively in a way that materially reduces your rights without notice and, where required, your consent.

2) Definitions

“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked (directly or indirectly) with a particular individual. Examples include email address and information submitted through our forms.

“Usage Data” means information collected automatically about how you access and use the Services (for example, IP address, browser type, device identifiers, pages visited, referring/exit pages, and timestamps).

3) Information We Collect

We collect information in three main ways: (A) information you provide, (B) information others provide about you in the course of using Encircled (e.g., a guide or student entering a mentor’s email), and (C) information collected automatically.

A. Information you provide directly

Depending on how you use the Services, you may provide:

  1. Email addresses and contact details
    • Your email address when you initiate a mentor circle plan
    • Your email address when you subscribe to our listserve
    • Your email address if you contact us for help or information
  2. Form responses related to Encircled activities - We collect information entered by a student, guide, parent, or mentor into Encircled forms, including information associated with:
    • Student activities (the “four student activities”)
    • Mentor activities (the “three mentor activities”)

These may include written responses, selections, reflections, encouragements/commitments, and similar activity content.

B. Information others provide about you

Encircled’s mentor circle planning process may involve one person entering another person’s contact information so that Encircled can invite or include them in a plan or activity.

For example, we may collect:

  • A guide’s email address entered by the plan initiator
  • Student and parent email addresses entered by a guide
  • Mentor email addresses entered by the student or a guide

Important If you submit someone else’s Personal Information to Encircled (such as an email address), you represent that you have the authority to do so and that it is appropriate for Encircled to contact them for the purpose you are initiating (for example, inviting them to participate in a mentor circle plan).

C. Information collected automatically (Usage Data)

When you access the Services, we may automatically collect Usage Data, such as:

  • IP address and general location (approximate)
  • Device type and identifiers
  • Browser type and operating system
  • Pages viewed and interactions
  • Referring/exit pages and timestamps

Some Usage Data may be treated as Personal Information depending on where you live and how it is used.

4) How We Use Information

We use Personal Information and Usage Data for the following purposes:

  1. To provide and operate the Services
    • Create and manage mentor circle plans and invitations
    • Route emails and notifications related to participation
    • Support the completion and storage of activity submissions (student and mentor activities)
  2. To communicate with you
    • Send messages necessary to deliver the Services (e.g., invitations, confirmations, service notices)
    • Respond to requests and provide support
  3. To send newsletters and updates (listserve)
    • Send you our newsletter and other communications if you subscribe
    • We use Mailchimp to manage our mailing list (see Section 6)
  4. To improve and protect the Services
    • Understand usage trends and improve site performance
    • Maintain security, prevent fraud/abuse, and enforce policies
    • Debug, troubleshoot, and monitor reliability
  5. To comply with legal obligations
    • Comply with applicable laws, lawful requests, and enforceable legal process
    • Protect rights, safety, and property of Encircled and others

5) Legal Bases for Processing (for individuals in the EEA/UK and similar jurisdictions)

Where required, Encircled processes Personal Information under one or more of these legal bases:

  • Consent (e.g., subscribing to the listserve; where consent is otherwise requested)
  • Contract / steps at your request before a contract (e.g., providing Services you request)
  • Legitimate interests (e.g., operating, securing, and improving the Services, and communicating necessary service information), balanced against your rights
  • Legal obligation (e.g., compliance and recordkeeping where applicable)

If we rely on consent, you may withdraw it at any time (see Section 10).

6) How We Share Information

We do not sell Personal Information for money. We share Personal Information only as described below:

A. Service providers (“processors”)

We share information with trusted vendors that help us operate the Services. These providers may process Personal Information only on our instructions and for the purposes we authorize.

Examples include:

  • Email marketing / list management Mailchimp (Rocket Science Group LLC) for newsletter/listserve communications
  • Website hosting, database, security, analytics, and communications tools (as applicable to our stack)

B. Legal and safety disclosures

We may disclose information if we believe in good faith that disclosure is necessary to:

  • Comply with law, regulation, subpoena, court order, or governmental request
  • Protect the security and integrity of the Services
  • Protect the rights, property, and safety of Encircled, our users, or others
  • Enforce our agreements and policies

C. Business transfers

If Encircled is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale/transfer of assets, information may be transferred as part of that transaction, subject to appropriate confidentiality protections and notice where required.

7) Cookies and Similar Technologies

We may use cookies and similar technologies to operate the Services and help us understand how the Services are used.

  • Essential cookies: required for core functionality and security
  • Analytics cookies (if enabled): help us understand usage and improve the Services

You can control cookies through your browser settings and may be able to limit certain tracking by disabling cookies. Note that some features may not function properly if you disable essential cookies.

Do Not Track: Because browser “Do Not Track” signals are not uniform, the Services may not respond to them consistently.

8) Data Retention

We retain Personal Information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Services, maintain records, resolve disputes, enforce agreements, and comply with legal obligations.

Mailing list retention We store listserve subscriber emails in Mailchimp and keep them as long as permitted and necessary for communications, unless you unsubscribe or request deletion where applicable.

We may retain de-identified or aggregated information for longer periods.

9) Security

We use administrative, technical, and physical safeguards designed to protect Personal Information. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. You use the Services and provide information at your own risk.

10) Your Choices and Rights

A. Email communications

  • Listserve/newsletters: You can unsubscribe using the “unsubscribe” link in our emails.
  • Even if you unsubscribe from marketing communications, we may still send non-marketing messages necessary to provide the Services (e.g., service updates, security notices).

B. Access, correction, deletion

Depending on where you live, you may have the right to:

  • Request access to the Personal Information we hold about you
  • Request correction of inaccurate Personal Information
  • Request deletion of your Personal Information (subject to legal exceptions)
  • Object to or restrict certain processing (in some jurisdictions)
  • Request portability (in some jurisdictions)

How to exercise rights: Email us at info@encircled.org (or your designated privacy contact). We may need to verify your identity before responding.

C. California privacy rights (CCPA/CPRA)

If you are a California resident, you may have rights to know, delete, correct, and to opt out of certain “sales” or “sharing” of Personal Information (as those terms are defined by California law), and to not be discriminated against for exercising these rights.

Encircled’s position: Encircled does not sell Personal Information for money. We also do not share Personal Information for cross-context behavioral advertising in the ordinary course of operating our mentor-circle and listserve features. If our practices change, we will update this Privacy Policy and provide any required opt-out mechanisms.

You (or an authorized agent) can submit a request by emailing info@encircled.org. We may require proof of authorization and will verify your identity before fulfilling requests.

D. EEA/UK and similar regions

If you are in the EEA/UK, you may have rights under GDPR, including the right to be informed, access, rectification, erasure, restriction, objection, and data portability.

You also have the right to lodge a complaint with your local supervisory authority.

11) Children and Youth Privacy

Encircled’s mission may involve students and youth participating in mentor-circle activities. We take youth privacy seriously.

  • The Services are not intended for children under 13 to use on their own without involvement of a parent/guardian or authorized adult guide, as applicable.
  • We do not knowingly collect Personal Information online from children under 13 without appropriate authorization and consent where required.

If you believe we have collected Personal Information from a child under 13 in a manner that is not authorized, please contact info@encircled.org and we will take appropriate steps (which may include deletion).

Note: If a parent/guardian or authorized guide submits a child’s information as part of mentor-circle planning, we treat that submission as being made by an authorized adult for the purpose of facilitating the Services.

12) Links to Third-Party Services

The Services may include links to third-party websites or services. This Privacy Policy does not apply to third-party practices. We encourage you to review the privacy policies of any third-party site you visit.

13) International Users

If you access the Services from outside the United States, you understand that your information may be processed in the United States or other locations where our vendors operate. Where required, we use appropriate safeguards for cross-border transfers (for example, contractual protections used by vendors).

14) Contact Us

If you have questions or requests regarding privacy, contact:

Encircled
Email: info@encircled.org
Mailing Address: 3452 County Road 101, Minnetonka, MN 55345