Privacy Policy

AL Circle Private Limited (“AL Circle”, “we”, “us”, “our”) is committed to safeguarding your privacy and protecting your personal data. This Privacy Policy applies to all personal data collected through:

  • https://www.alcircle.com
  • https://www.alcirclebiz.com
  • any subdomain of alcircle.com
  • all related products, services, newsletters, events and communications

(collectively, the “Platforms”).

We act as:

  • Data Controller under the General Data Protection Regulation (“GDPR”) for users located in the European Union / European Economic Area (“EU/EEA”).
  • Data Fiduciary under the Digital Personal Data Protection Act, 2023 (“DPDP Act”) for users located in India.

This Policy explains how we collect, use, disclose, process, store, retain and protect your personal data. If you do not agree with this Policy, please do not use our Platforms or provide personal data.

  • Personal Data – any information relating to an identified or identifiable individual.
  • Business Contact Information – professional contact details such as work email and job title (treated as Personal Data under GDPR and DPDP).
  • Processing – any operation performed on personal data, including collection, storage, use, disclosure or deletion.
  • Data Subject / Data Principal – the individual whose personal data is processed.

A. Identity & Business Information

  • Full name
  • Job title / designation
  • Company name and industry

B. Contact Information

  • Work / personal email address
  • Telephone and mobile number
  • Office / home address

C. Marketplace & Lead Data (alcirclebiz.com)

  • Buying leads and selling leads
  • Enquiry details
  • Messages exchanged between buyers and sellers
  • Transaction and communication history

D. Account & Profile Data

  • Username and encrypted password
  • Preferences and settings

E. Technical & Usage Data

  • IP address
  • Device type, browser type
  • Approximate location
  • Website clicks, pages visited and interaction data (in anonymised and aggregated form)

We collect personal data:

  • directly from you (forms, registrations, enquiries, subscriptions);
  • from gated downloads, events and tradeshows;
  • automatically via cookies and similar technologies; and
  • from public sources where permitted by law.

We process personal data based on one or more of the following:

  • Consent – newsletters, marketing, non-essential cookies.
  • Performance of a Contract – providing marketplace and platform services.
  • Legitimate Interests – improving services, facilitating B2B connections, fraud prevention, security.
  • Legal Obligation – compliance with applicable laws.

You may withdraw consent at any time.

We use personal data to:

  • provide requested services;
  • enable buyer–seller connections;
  • create and manage accounts;
  • respond to queries and feedback;
  • send newsletters and updates;
  • provide marketing communications (where permitted);
  • improve platform performance; and
  • comply with legal obligations.

When you submit a Buying Lead or Selling Lead on alcirclebiz.com:

  • you explicitly instruct us to share your Identity and Contact Data with the relevant counterparty;
  • this sharing is essential to facilitate business communication; and
  • AL Circle is not responsible for how another user processes your data once shared.

You will receive marketing communications only where:

  • you have provided consent; or
  • it is permitted by law.

Every marketing email contains an unsubscribe option.

We do not sell personal data. We may share data with:

A. Platform Users

  • Buyers / sellers you choose to engage with.

B. Service Providers (Data Processors)

  • Zoho – CRM
  • Constant Contact – email marketing
  • Mailchimp – newsletters
  • Zepto Mail – transactional emails
  • AWS – hosting and databases
  • WhatsApp – live chat support
  • Razorpay – payment processing
  • Google Analytics (or equivalent) – website analytics
  • LinkedIn / Meta / Google Ads – advertising and remarketing pixels

All service providers process data under contractual confidentiality and security obligations.

C. International Data Transfers

As a global platform headquartered in India, your personal data may be transferred to, stored, or processed in countries outside your country of residence, including India and the United States, where our servers and third-party service providers are located.

When we transfer personal data originating from the European Economic Area (EEA) or the United Kingdom (UK) to countries that have not been granted an adequacy decision by the European Commission, we rely on appropriate legal safeguards, including the execution of Standard Contractual Clauses (SCCs) approved by the European Commission or UK International Data Transfer Agreements (IDTA), or other legally recognized transfer mechanisms to ensure your data remains protected to international standards.

  • Personal data is retained while you maintain an active relationship with us.
  • If there has been no interaction for 36 months, data may be deleted or anonymised.
  • Client-provided data follows contractual retention requirements.

You have the right to:

  • access;
  • rectification;
  • erasure;
  • restriction;
  • objection;
  • data portability;
  • withdraw consent; and
  • lodge a complaint with your supervisory authority.

Your Rights (California – CCPA/CPRA):

If you are a California resident, you have the right to know what personal information we collect, to request deletion, to correct inaccurate information, and to opt out of the sale or sharing of personal information (note: AL Circle does not sell personal data, as stated in Section 9). You will not be discriminated against for exercising these rights.

You have the right to:

  • access personal data;
  • correction and erasure;
  • withdraw consent;
  • nominate another person; and
  • grievance redressal.

Where required under the DPDP Act, we will provide a clear and itemised notice at the point of collection describing the personal data collected and the purpose of processing.

Where you provide consent through a Consent Manager registered under the DPDP Act, you may manage, review or withdraw such consent through that platform.

If AL Circle is classified as a Significant Data Fiduciary under the DPDP Act, we will comply with additional obligations including appointment of a Data Protection Officer based in India and periodic Data Protection Impact Assessments.

We use reasonable technical and organisational safeguards including encryption, access controls and secure servers.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the applicable supervisory authority within the timeframe required by law (72 hours under GDPR) and, where required, notify affected individuals without undue delay. For users in India, we will comply with applicable breach reporting timelines under the DPDP Act and CERT-In directions (including the 6-hour reporting requirement to CERT-In for specified incidents, where applicable to us as an intermediary).

Cookies and Tracking Technologies

We use essential, functional, performance, and analytics cookies and similar tracking technologies to operate the Platforms, remember your preferences, analyze usage, and deliver tailored content.

Essential Cookies: Necessary for the website to function (e.g., keeping you logged into your single AL Circle Account). These cannot be switched off.

Non-Essential Cookies (Analytics & Marketing): Used to collect performance metrics and deliver personalized marketing. Where required by law (such as in the EU/UK), non-essential cookies are only deployed with your explicit prior consent.

You can manage or withdraw your cookie preferences at any time via the Cookie Preference Center available on our website footer, or by adjusting your browser settings. Please note that blocking essential cookies may impact the functionality of certain Platform features.

Our Platforms are intended for users aged 18 (eighteen) years and above.

We are not responsible for the privacy practices of external websites.

We may update this Policy periodically. Continued use of the Platforms constitutes acceptance of the revised Policy.

We respect the personal data and privacy of each of our users and value the trust they place in us. We will take every necessary step to make your browsing hassle-free. If you wish to make a complaint, comment or suggestion regarding the Platforms, or regarding any discrepancy in the processing of information, you may reach out to the officers below.

Grievance Redressal Officer — Name: — Arighna Sarkar | Email: — arighnas@alcircle.com

Data Protection Officer — Name: — Payel Bhattacharjee | Email: — payel@alcircle.com