Privacy Policy

Last Updated: September 2026

Circool Services Privacy Policy

Circool LLC ("Circool," "we," "us," or "our") provides technology that helps schools and other educational organizations manage interactions among their staff, families, students, visitors, and communities.

We understand that Schools, families, and Visitors entrust Circool with information that can be sensitive. Protecting that information and being clear about how it is accessed, used, stored, and disclosed is a responsibility we take seriously.

Our Commitment to Your Data

Your data is not our product.

Circool does not sell, rent, or trade personal information or Student Data.

Circool does not disclose personal information or Student Data to third parties for their own advertising, marketing, data brokerage, commercial, or other independent purposes.

Circool uses carefully selected service providers to perform limited functions necessary to operate and support the Services. Circool selects service providers that are contractually or otherwise obligated to process information consistently with applicable privacy and security requirements.

Circool may also transmit limited information to another service when specifically authorized by a School or organization to support an integration requested by that Customer.

This Services Privacy Policy explains what information Circool processes through the Circool Services, why we process it, when limited information may be processed by others on Circool's behalf or at a Customer's direction, how information is protected and retained, and how access, correction, and deletion requests are handled.

Scope of This Services Privacy Policy

This Services Privacy Policy applies to Circool products, services, applications, and technology used by Schools, organizations, staff, parents, guardians, Visitors, and other authorized adults, including, as applicable:

Circool's Progressive Web App and authenticated web application;
Circool's iOS and Android mobile applications;
School and district administrative interfaces;
Circool kiosks and check-in stations;
Guest and Visitor Management;
Student Check-In and Check-Out;
Event Management;
Emergency Reunification;
Circool QR passes and related credentials;
integrations with School systems and other Customer-authorized services;
implementation and training services;
support services; and
communications generated or delivered through the Circool Services.

Together, these are referred to as the "Services."

This Services Privacy Policy does not govern general browsing of Circool's public marketing website. Circool may maintain a separate Website Privacy Notice for information collected through its public website.

This Services Privacy Policy does not replace any agreement between Circool and a School or organization. Where Circool processes information on behalf of a Customer, Circool also follows the applicable agreement with that Customer.

Definitions

"Customer" means a School, school district, local educational agency, educational organization, or other organization that uses Circool under an agreement with Circool.

"School" means a school, school district, local educational agency, or other educational institution using the Services.

"Student Data" means personally identifiable information regarding a student that Circool receives from or processes on behalf of a Customer in connection with the Services.

"User" means an authorized adult who has been invited, provisioned, or permitted to activate and use a Circool account, such as a parent, guardian, School employee, approved family member, friend, or other authorized adult.

"Visitor" means an individual whose information is processed through Circool in connection with visiting or accessing a School or organization, whether or not that individual has an activated Circool account.

3. Customer Ownership and Control of Data

Personal information, Student Data, Visitor Data, and other records provided to or processed by Circool on behalf of a School or organization remain under the ownership and control of that School or organization, subject to applicable law.

Circool processes that information as a service provider on the Customer's behalf and does not claim ownership of it.

For information Circool processes on behalf of a School or organization, the applicable Customer generally determines whether the information should be accessed, corrected, retained, or deleted.

Circool will support authorized requests and instructions from the Customer in accordance with applicable law and Circool's agreements.

Schools Control School and Student Data

Circool provides Services to Schools and processes Student Data on their behalf.

Schools determine which Circool Services they use and what School and Student Data is provided to or made available through Circool.

Depending on the Services used by a School, Circool may receive information:

directly from the School;
through an authorized integration with the School's student information system or another School system;
from authorized School personnel;
from an authorized parent or guardian; or
through use of the Services.

Circool uses Student Data only to provide, operate, secure, support, maintain, and improve the Services provided to the School and as otherwise directed or authorized by the School or permitted by applicable law.

Circool does not sell Student Data.

Circool does not use Student Data for targeted advertising.

Circool does not disclose Student Data to third parties for their own marketing, advertising, data brokerage, or independent commercial use.

Additional information regarding the categories of Student Data processed for a particular School may be made available to the School upon request and appropriate authorization

Information Circool Collects and Processes

The information Circool processes depends on the Services being used and an individual's relationship with the applicable Customer.

A. School and Student Information

Circool may receive Student Data and related School information through authorized integrations and directly from Schools.

This may include information necessary to:

identify a student;
associate the student with the appropriate School;
associate the student with authorized parents, guardians, or other individuals;
determine relationships or permissions relevant to a School workflow;
support attendance, arrival, dismissal, event, reunification, or other School-directed functions; and
provide the Services selected by the School.

Circool may also create records associated with use of the Services, including records concerning check-ins, check-outs, arrivals, departures, events, reunification, and other School-directed workflows.

The specific information processed may vary by School based on the Services selected, the School's systems, and the School's configuration of Circool.

B. Guardian Account Records

When a School provides guardian information to Circool through an authorized student information system integration, Circool may create a provisional account record for an active custodial guardian.

The guardian may optionally activate the account.

A guardian does not have access to the Circool account until the guardian chooses to activate it and completes Circool's verification process, which may include confirming date of birth and providing a profile photograph.

A guardian is not required to activate a Circool account merely because the School has provided guardian information to Circool.

C. Adult User Information

Circool accounts are not available through open public registration.

Depending on the User and Services being used, Circool may process information such as:

first and last name;
email address;
telephone number;
date of birth;
account and authentication information;
relationship to a student or School;
School affiliation;
profile photograph or selfie;
Circool pass or QR information;
communication preferences; and
information the User chooses to enter into Circool.

Circool may also process information necessary to authenticate Users, verify account ownership, and protect accounts.

D. Family and Friend Information and Invitations

An authorized parent or guardian may manually enter limited information about a family member or friend, such as the person's first name, last name, and relationship, and initiate an invitation to that person.

If the parent chooses to share the invitation by text message, email, or another supported communication method, Circool may prepare the invitation content or link and allow the parent to send it using an application available on the parent's own device.

Circool does not access the parent's address book, select the recipient from the parent's contacts, or press "send" on the parent's behalf.

The parent controls the communication and sends it through the parent's own device and selected communication service.

An invited adult who chooses to activate a Circool account must verify or complete information associated with the account, which may include date of birth and an email address or telephone number.

E. Visitor Information

When a person visits a Customer location using Circool, Circool may process information needed by the Customer to identify, verify, screen, and manage the Visitor.

Depending on the circumstances, this may include:

first and last name;
date of birth;
profile photograph or selfie;
School or location being visited;
date and time of the visit;
purpose or status of the visit;
screening information;
information obtained from government-issued identification; and
other information entered by the Visitor or authorized Customer personnel as part of the check-in process.

Visitor records may be retained for the duration of the applicable Customer's relationship with Circool unless the Customer requests earlier deletion or another retention requirement applies.

Government-Issued Identification

When a Visitor presents a driver's license, passport, or other supported government-issued identification, Circool may process information from the identification as part of the Visitor verification and screening process.

Information obtained from an identification document may include:

name;
date of birth;
photograph appearing on the identification;
expiration date;
identification type; and
issuing state or jurisdiction.

Circool does not capture or retain the driver's license number, passport number, or other identification document number.

Circool does not retain the individual's home address from the identification.

Circool is designed to remove government-issued identification information within 30 days.

A photograph obtained from a government-issued identification document is treated as government-issued identification information and follows the applicable identification-retention process.

A profile photograph or selfie separately provided or captured for the User or Visitor is maintained separately and may be retained as part of the individual's Circool profile or Visitor record for the duration of the applicable Customer's relationship with Circool, unless deleted earlier.

Sex Offender Registry Screening

When a Customer uses Circool to perform a sex-offender screening, Circool provides a service provider with only the individual's:

first name;
last name; and
date of birth.

The service provider compares that information against publicly available sex-offender registry information to identify potential matches.

Circool does not provide the screening provider with the individual's photograph, government identification image, home address, document number, or other personal information for this purpose.

When a screening does not identify a potential match, Circool does not retain additional source-registry information about the individual.

When a potential positive match is identified, Circool may retain information relating to the matching public registry record and the screening result as part of the Customer's Visitor-management records.

Circool selects service providers that are contractually or otherwise obligated to process information consistently with applicable privacy and security requirements.

Customer-Authorized Integrations

A Customer may choose to connect Circool with another technology service already used or authorized by that Customer.

At the Customer's direction, Circool may transmit limited information to that service when necessary to enable the authorized integration.

For example, an integration may use a common unique identifier already maintained by both systems to match the correct student or record without Circool providing additional information that is unnecessary for the integration.

Circool does not independently enable these integrations for its own advertising, marketing, or commercial purposes.

The Customer controls whether the applicable integration is authorized and used.

Communications and Support Information

Circool may process information provided by a User, Visitor, Customer, or Customer employee when communicating with Circool for:

implementation;
training;
customer service;
technical support;
troubleshooting;
security;
account assistance; or
other operational purposes.

This may include contact information, support messages, screenshots, diagnostic information provided to Circool, and information necessary to investigate or resolve a request.

Circool may retain operational, support, communication, security, and system records as reasonably necessary to:

maintain service history;
troubleshoot issues;
support Customers;
protect the Services;
improve Circool's internal knowledge and support resources; and
comply with contractual or legal obligations.

Technical and Usage Information

When the Services are used, Circool may process limited technical information necessary to operate, secure, troubleshoot, support, and maintain the Services.

Depending on the platform and method of access, this may include information such as:

IP address;
browser type;
device type;
operating system;
application version;
timestamps;
authentication and security events;
server logs;
error or diagnostic information; and
information regarding interactions with the Services.

Circool does not use this information for third-party advertising.

How Circool Uses Information

Circool uses information for purposes related to providing and supporting the Services, including:

providing the Services selected by Customers;
authenticating Users and protecting accounts;
verifying Users and Visitors;
performing Customer-directed Visitor screening;
supporting student check-in and check-out;
supporting Customer events;
supporting emergency reunification;
managing Circool passes and credentials;
sending service-related and Customer-directed communications;
providing implementation, training, and customer support;
troubleshooting technical problems;
protecting against misuse, fraud, and security incidents;
maintaining the security and reliability of the Services;
evaluating product and service utilization;
identifying Customers that may need implementation, training, or support assistance;
improving Circool's products and services;
complying with contractual obligations; and
complying with applicable law.

Circool does not use Student Data or personal information to build third-party advertising profiles or enable targeted advertising.

Circool Does Not Sell or Disclose Data for Independent Use

Circool does not sell, rent, or trade personal information or Student Data.

Circool does not provide personal information or Student Data to another company for that company's own:

advertising;
marketing;
data brokerage;
profiling;
commercial exploitation; or
other independent use.

Limited information may be processed outside Circool's own systems only when necessary to provide or support the Services, when directed by a Customer through an authorized integration, as part of a permitted business transaction, or when disclosure is otherwise required or permitted by law as described in this Services Privacy Policy.

Service Providers Acting on Circool's Behalf

Circool uses service providers to perform limited functions necessary to operate, deliver, support, and protect the Services.

These may include providers supporting functions such as:

cloud hosting and infrastructure;
authentication;
email and SMS delivery;
Visitor screening;
security;
system monitoring;
technical support; and
related operational infrastructure.

Circool limits information provided to service providers based on the function being performed.

Circool selects service providers that are contractually or otherwise obligated to process information consistently with applicable privacy and security requirements.

Circool does not authorize its service providers to use Circool personal information or Student Data for their own independent advertising, marketing, or commercial purposes.

Circool Mobile Applications

Circool provides mobile applications for authorized adult Users.

Camera Access

The Circool mobile application may request permission to use a device's camera during account activation or when a User chooses to add or update a profile photograph.

Circool does not access the device camera without permission provided through the device's operating system.

Users may control camera permissions through their device settings, although disabling camera access may prevent certain features from functioning.

School-Side Camera Use

Separate from the parent-facing mobile application, authorized Customer employees using Circool's web-based Services may use a device camera for functions such as:

scanning Circool QR codes;
capturing Visitor photographs;
capturing supported government-issued identification; or
performing other Customer-directed check-in functions.

Location

Circool does not collect precise or approximate device location through the Circool mobile application and does not request device location permission.

An IP address may be processed as part of ordinary Internet communications, security, system logs, or technical operations. Circool does not use this as GPS or device-location tracking.

Device Contacts

Circool does not access or upload a User's mobile device contacts.

Information about parents, guardians, approved family members, friends, or other individuals available within Circool comes from authorized Customer systems or information manually provided through Circool.

Passkeys and Device Authentication

Circool may support passkey-based authentication.

A device or operating-system provider may allow a User to authorize a passkey using a fingerprint, facial recognition, device PIN, password, or another authentication mechanism.

Circool does not receive or store a User's fingerprint, facial-recognition template, or other biometric authentication data merely because the User's device uses that information to authorize a passkey.

Circool does not use facial recognition, facial geometry, or other biometric identification technology as part of its Services.

Apple App Store and Google Play

When a User downloads, installs, or updates Circool through the Apple App Store or Google Play, Apple or Google may independently collect or process information associated with the User's use of their store, device, operating system, or related services.

That activity is governed by the applicable platform provider's own privacy practices.

Circool may receive limited information from those platforms that is necessary to distribute, maintain, secure, troubleshoot, or understand the technical performance of the Circool application.

Circool does not control information independently collected by Apple or Google through their own products and services.

Email Communications

Circool may send email communications necessary to provide the Services or communications requested or configured by a Customer.

These may include:

account activation messages;
authentication and security messages;
administrative notifications;
event invitations and reminders;
emergency and reunification communications;
messages associated with Customer workflows;
customer support messages; and
other operational communications.

Circool may use service providers to deliver email communications on Circool's behalf.

Where applicable, Users may manage communication preferences through Circool, the applicable Customer, or instructions contained in the communication.

Certain account, security, legal, emergency, or Customer-directed communications may be necessary to provide the Services even when other communications have been disabled.

SMS and Text Communications

Circool may send SMS messages necessary to provide the Services or messages requested or configured by a Customer.

These may include:

account activation messages;
authentication or security messages;
administrative notifications;
event invitations and reminders;
emergency and reunification communications;
messages associated with Customer workflows; and
other operational communications.

Message frequency may vary. Message and data rates may apply.

Users may opt out of eligible SMS messages at any time by replying STOP.

Users may reply HELP for assistance.

Circool and its messaging providers may also recognize other reasonable opt-out terms as required by applicable law or messaging-industry standards.

Opting out of SMS messages may prevent Circool or the applicable Customer from delivering certain notifications by text message. Where appropriate, the Customer may use another available communication method.

Authenticated Web Technologies

Circool's authenticated web Services may use cookies, local storage, server logs, or similar technologies necessary to:

authenticate Users;
maintain sessions;
remember preferences;
secure the Services;
diagnose technical issues; and
understand and improve use of the Services.

Disabling technologies necessary for authentication or operation may prevent portions of Circool from functioning correctly.

Circool does not use Student Data for behavioral advertising.

Aggregate and De-Identified Information

Circool may create aggregated or de-identified information from information processed through the Services when that information no longer reasonably identifies a particular individual.

Circool may use aggregated or de-identified information internally to:

monitor system and Customer utilization;
identify Customers that may need implementation, training, or support assistance;
evaluate service performance;
develop internal reporting and benchmarking;
improve Circool's products and services; and
support internal operational planning.

Circool does not sell aggregated or de-identified information.

Circool does not attempt to re-identify information that has been properly de-identified except when reasonably necessary to test, validate, or protect the effectiveness of the de-identification process or as otherwise permitted by law.

Data Retention

Circool retains information based on the purpose for which it is processed, the Services being provided, the Customer's relationship with Circool, security and support requirements, and applicable contractual or legal obligations.

Different categories of information may have different retention periods.

Circool may retain operational, support, communication, security, screening, and system records as reasonably necessary to:

maintain service history;
provide support;
troubleshoot issues;
protect Circool and its Customers;
maintain internal reference and knowledge resources;
support the reliability of the Services; and
satisfy contractual or legal requirements.

Circool is designed to remove government-issued identification information within 30 days.

Visitor records and profile photographs may be retained for the duration of the applicable Customer's relationship with Circool unless deleted earlier.

Inactive accounts may be disabled when appropriate.

Visitor Data Deletion Requests

If you would like Visitor information associated with a School or organization visit to be deleted from Circool, you should submit a written request directly to the School or organization you visited.

The applicable School or organization controls the Visitor records processed by Circool and has the authority to direct Circool to delete those records, subject to applicable law, contractual requirements, and any information that must be retained for legitimate security or legal purposes.

Circool will cooperate with authorized deletion instructions received from the applicable School or organization.

Account Deactivation and Deletion Requests

Circool accounts are invitation-based and are not available through open public registration.

Circool may create provisional account records based on information provided by an authorized Customer or an authorized User, but the individual must choose to activate the account before using it.

An authorized adult User may request deactivation or deletion of the User's Circool account through available Circool account controls or by contacting Circool or the applicable Customer.

Circool may need to verify the identity and authority of the person making the request before acting on it.

Deleting an adult User's Circool account does not necessarily require deletion of Student Data or Customer records associated with that User.

Customers generally control Student Data and other Customer records processed by Circool on their behalf.

A parent, guardian, eligible student, Visitor, or other individual seeking access to, correction of, or deletion of Customer-controlled information may be directed to the applicable Customer so that the Customer can determine the appropriate response.

Circool will cooperate with authorized Customer instructions in accordance with applicable law and Circool's agreements.

Circool may retain limited information when retention is required by law or reasonably necessary to protect the security and integrity of the Services, investigate misuse, or satisfy another legal obligation.

Contract Termination and Deletion of Customer Data

When a Customer's agreement with Circool terminates, Circool deletes the Customer's personal information, Student Data, Visitor Data, and other Customer-associated data within 30 days or sooner, unless Circool is legally required to retain particular information.

Backup copies may persist for a limited period during that process and are generally overwritten or deleted through Circool's normal backup lifecycle.

Customer-associated backup data is also removed as part of Circool's termination and deletion process.

Circool does not retain terminated Customer data for future advertising, marketing, sale, or unrelated commercial use.

Security

Circool maintains administrative, technical, and organizational safeguards designed to protect information against unauthorized access, use, disclosure, alteration, or destruction.

Circool's security program includes practices such as:

periodic risk assessments;
vulnerability scanning;
security reviews;
incident-response planning and exercises; and
administrative and technical safeguards appropriate to the nature of the Services and information being processed.

Circool works to identify and address security risks as they are discovered.

No system connected to the Internet can be guaranteed to be completely secure. Circool therefore cannot guarantee that unauthorized access, disclosure, or security incidents will never occur.

If Circool becomes aware of a security incident affecting protected information, Circool will respond in accordance with its contractual obligations and applicable law.

FERPA and Education Records

Circool provides technology services to educational institutions and may process education records and Student Data on behalf of Schools.

Where the Family Educational Rights and Privacy Act ("FERPA") applies, Circool processes education records in a manner intended to support the School's compliance with FERPA and the School's obligations concerning access to and use of education records.

Schools may engage Circool as a service provider performing institutional services or functions on the School's behalf, subject to the applicable agreement and legal requirements.

Circool does not claim ownership of Student Data provided by a School.

Schools retain ownership and control of their Student Data subject to applicable law and their agreements with Circool.

Circool does not represent that it has received a governmental certification of FERPA compliance.

Children and Student Information

Circool user accounts are intended for authorized adults.

Students and children are not permitted to independently create or activate Circool user accounts.

Circool may nevertheless process information about students, including children under the age of 13, when that information is provided or authorized by a School in connection with the School's use of the Services.

Where the Children's Online Privacy Protection Act ("COPPA") applies, Circool processes children's personal information on behalf of and at the direction of the applicable School for School-authorized purposes.

Circool does not knowingly:

allow children to independently register for Circool accounts;
sell children's personal information;
use children's personal information for behavioral advertising; or
disclose children's personal information for third-party independent marketing or commercial use.

Legal Requirements and Safety

Circool may preserve, access, or disclose information when Circool reasonably believes doing so is required by applicable law, regulation, subpoena, court order, or other valid legal process.

Circool may also process or disclose information when reasonably necessary and legally permitted to:

protect the security or integrity of Circool;
investigate fraud, misuse, or unlawful activity;
protect the rights, safety, or property of Circool, a Customer, a User, a student, or another person; or
respond to an emergency involving a threat to health or safety.

Circool does not voluntarily disclose personal information to third parties for unrelated commercial purposes.

Business Transactions

If Circool is involved in a merger, acquisition, financing, reorganization, sale of assets, or similar corporate transaction, information may be transferred as part of that transaction, subject to applicable law, contractual obligations, and continued protection consistent with this Services Privacy Policy.

Changes to This Services Privacy Policy

Circool may update this Services Privacy Policy from time to time to reflect:

changes to the Services;
new technology or features;
changes to Circool's data practices;
legal or regulatory developments; or
improvements to the clarity of this policy.

When Circool makes changes, Circool will update the Last Updated date at the top of this Services Privacy Policy.

Circool may provide additional notice when appropriate based on the nature of a change.

Contact Circool

Questions about this Services Privacy Policy, Circool's privacy practices, or requests concerning a Circool account may be directed to:

Circool LLC
Attn: Privacy
Email: info@circool.com

Questions concerning Student Data, Visitor Data, education records, or other information controlled by a Customer may also be directed to the applicable School, district, or organization.