Privacy Policy

Last updated: January 1, 2026

Xiamen Mitukes Technology Co., Ltd. ("CirCow", "we", "us") respects your privacy. This Privacy Policy explains what information we collect, how we use it, and the choices you have.

1. Information We Collect

1.1 Information You Provide

• Account information: name, email address, password, and billing details when you register or subscribe.
• Communications: messages you send to support, feedback, and survey responses.
• User content: prompts, files, and configurations you submit when using AI workers (most of which stays local on your device — see Section 4).

1.2 Information Collected Automatically

• Usage data: features used, worker runs, timestamps, and error logs.
• Device data: operating system, client version, IP address, browser type.
• Cookies: session cookies and analytics cookies for essential website functionality.

1.3 Information from Third Parties

• Payment processors: billing status (we do not store full card numbers; payments are processed by our PCI-DSS certified payment partner).
• AI model providers: if you bring your own model API key, your prompts are sent to that provider per their terms.

2. How We Use Information

• To provide, maintain, and improve the Service.
• To process payments and manage subscriptions.
• To send transactional and service-related emails (e.g. receipts, security alerts).
• To respond to support requests.
• To detect, prevent, and address fraud, abuse, or technical issues.
• To comply with legal obligations.

3. Legal Bases (GDPR)

If you are in the European Economic Area, we process your personal data under the following bases: (a) performance of a contract; (b) our legitimate interests in operating the Service; (c) compliance with legal obligations; and (d) your consent where required.

4. Local-First Architecture

CirCow workers run on your own computer. By default, your prompts, files, and worker outputs stay on your device. We collect server-side only the metadata necessary to operate the Service (account, billing, usage counts, and error logs). User content is not transmitted to us unless you explicitly share it (for example, attaching a file in a support email or syncing to your account).

5. Service Providers (Sub-processors)

We do not sell your personal information. We share information only with the following categories of trusted service providers, under contractual confidentiality and data-protection obligations:

• Cloud hosting and CDN: for serving the website and storing operational data.
• Payment processing: a PCI-DSS certified payment partner that handles card data; we never store full card numbers.
• Transactional email: for sending receipts, password resets, and service notifications.
• Analytics: for aggregate, privacy-respecting usage analytics on the website.
• Error tracking and observability: for diagnosing application errors.
• Customer support tools: for managing inbound support emails and tickets.

A current list of named sub-processors is available on request — email support@circow.com.

6. Legal Disclosures and Business Transfers

• Legal authorities: we may disclose information when required by applicable law, subpoena, or court order.
• Business transfers: in connection with a merger, acquisition, or asset sale, where data is transferred subject to this Policy.

7. Data Retention

We retain your personal data for as long as your account is active and for a reasonable period thereafter to comply with legal obligations, resolve disputes, and enforce agreements. You may request deletion of your account and associated data at any time.

8. Data Security

We implement industry-standard technical and organizational measures to protect your data, including encryption in transit (TLS 1.2+), access controls, audit logging, and regular security reviews. No method of transmission or storage is 100% secure, but we work hard to protect your information.

9. International Data Transfers

Your information may be processed in countries other than your own. Where required by law, we use appropriate safeguards (such as the EU Standard Contractual Clauses) for cross-border transfers.

10. Your Rights

Depending on your jurisdiction, you may have the right to:

• Access the personal data we hold about you.
• Request correction or deletion of your data.
• Object to or restrict certain processing.
• Request data portability.
• Withdraw consent where processing is based on consent.
• Lodge a complaint with a supervisory authority.

To exercise these rights, email support@circow.com. We respond within 30 days as required by GDPR.

11. Children's Privacy

The Service is not directed to children under 16. We do not knowingly collect personal data from children. If you believe a child has provided us data, please contact us so we can delete it.

12. Cookies

We use essential cookies for authentication and limited analytics cookies to understand site usage. You can disable cookies in your browser settings; some features may not work as intended.

13. Third-Party Links

The Service may link to third-party websites. This Policy does not apply to those sites; please review their privacy policies separately.

14. Changes to This Policy

We may update this Policy from time to time. We will post the updated version on this page and update the "Last updated" date. Material changes will be communicated via email or in-product notice.

15. Contact