PRIVACY POLICY
Last updated: May 8 2026
1. Introduction
TheICircle International Ltd, together with its affiliates and service providers involved in delivering TheICircle services (“TheICircle”, “we”, “us”, “our”), is committed to protecting your privacy and handling your personal data in a transparent, lawful and secure manner.
This Privacy Policy explains how we collect, use, share and protect personal data when you visit theicircle.co, interact with us, submit forms, apply as a Host or Student, use our services, or otherwise engage with the TheICircle platform, communications and related activities.
For users located in the European Economic Area (EEA), the United Kingdom and Switzerland, we also explain how cookies, similar technologies, analytics tools and advertising technologies are used, including for measurement, advertising and ads personalization, where applicable and where consent has been given.
Google requires users in these regions to be clearly informed about the use of cookies and personal data for advertising, analytics, ad measurement and ads personalization purposes.
2. Who we are
This website and the related TheICircle services are operated by:
TheICircle International Ltd
Quadrant House, Floor 6
4 Thomas More Square
London E1W 1YW
United Kingdom
Email: hello@theicircle.co
For operational activities within the European Union, TheICircle may also act through its appointed EU service provider:
NEWW S.r.l.
Via Flaminia 362
00196 Rome
Italy
For privacy-related requests, users may contact:
Depending on the specific service, booking flow or operational activity involved, TheICircle International Ltd and/or NEWW S.r.l. may act as independent data controllers or coordinated service providers for the purposes described in this Privacy Policy.
3. Personal data we collect
We may collect and process the following categories of personal data:
identity data, such as first name, last name, date of birth, nationality, gender and profile information;
contact data, such as email address, phone number, home address and city;
application and matching data, such as school or university details, program details, stay preferences, accommodation preferences, dietary, cultural or lifestyle information relevant to the requested service;
booking and payment-related data, such as booking details, payment status, transaction references and related administrative records;
communications data, such as messages, forms, support requests, feedback and survey responses;
document and verification data, where relevant, such as identity documents, proof of address, property or accommodation-related information and compliance checks;
technical data, such as IP address, browser type, device identifiers, log data, cookie identifiers, advertising identifiers and information about how you interact with our website;
marketing and consent data, such as your communication preferences and your choices regarding cookies, analytics, advertising and ads personalization.
In some cases, and only where necessary for the requested service or legal compliance, we may also process limited categories of special-category data, such as health-related or dietary information, where you choose to provide them and where permitted by applicable law.
4. How we collect personal data
We collect personal data:
directly from you, when you fill in forms, contact us, apply for a service, make a booking, submit documents, subscribe to communications or otherwise interact with us;
from other users, where they provide your information in relation to a booking, referral, invitation, host/student matching process or shared accommodation arrangement;
from service providers and partners who support identity verification, payment processing, fraud prevention, CRM, analytics, advertising and website functionality;
through cookies and similar technologies on our website, subject to your consent choices where required by law.
If you log in or interact through third-party services or platforms, we may receive data from those services in accordance with their privacy settings and your choices.
5. How we use your personal data
a. To provide our services
We process personal data to manage applications, evaluate host and student profiles, perform matching activities, administer bookings, manage accommodation-related services, communicate with users, provide customer support and operate the TheICircle platform.
b. To manage payments and administration
We process data to administer booking fees, recurring payments, receipts, refunds where applicable, fraud checks, financial reconciliation and related legal or accounting obligations.
c. To improve our platform and operations
We may use data to troubleshoot, analyze usage, improve service quality, optimize workflows, conduct research, develop our products and improve internal operational processes.
d. To keep the platform safe and reliable
We may process data to verify identity, prevent fraud, detect suspicious activity, enforce our terms and policies, handle disputes, comply with safeguarding obligations and protect the rights, safety and legitimate interests of TheICircle, its users and third parties.
e. To send service and marketing communications
We may send operational messages, account communications, updates, customer care messages and, where permitted, marketing communications about our services, offers, events or opportunities.
You can opt out of marketing communications at any time.
f. To measure, improve and personalize advertising
Where permitted and, where required, based on your consent, we and our partners may use cookies, pixels, tags, advertising identifiers and similar technologies to:
measure the performance of advertising campaigns;
understand conversions and website interactions;
show non-personalized advertising;
show personalized advertising;
support ads personalization, including remarketing and the tailoring of advertising based on your interactions, preferences, browsing behavior and identifiers.
For users in the EEA, UK and Switzerland, we aim to collect and pass consent choices to Google and other relevant vendors through an appropriate consent mechanism.
Google requires advertisers using its services to inform users that personal data, cookies and advertising identifiers may be used for ad measurement and ads personalization.
6. Legal bases for processing
Where applicable under GDPR and similar laws, we rely on one or more of the following legal bases:
performance of a contract, where processing is necessary to provide requested services;
compliance with legal obligations, including accounting, tax, AML, fraud prevention and regulatory compliance;
legitimate interests, where processing is necessary for platform administration, security, service improvement and certain business operations, provided such interests are not overridden by your rights;
consent, where required by law, including for certain marketing activities and the use of cookies, analytics, advertising technologies and ads personalization.
You may withdraw consent at any time for future processing, including by changing your cookie preferences or contacting us.
7. Cookies, consent and online tracking technologies
We use cookies and similar technologies, including tags, pixels, SDKs, local storage and analytics tools, to operate our website and measure performance.
These technologies may be used for the following categories of purposes:
strictly necessary website functionality;
preferences and functionality;
analytics and measurement;
advertising and ad measurement;
personalized advertising and ads personalization.
For users in the EEA, UK and Switzerland:
cookies or similar technologies used for analytics, advertising, ad measurement and ads personalization are only activated where required after the user has given the relevant consent through our consent banner or consent management platform;
we inform users on the first layer of the banner that cookies and personal data may be used for personalized and non-personalized advertising;
we seek to ensure that Google consent signals are transmitted in line with users’ choices through Consent Mode or another supported framework where implemented.
Google states that Consent Mode is used to communicate users’ consent choices to Google tags, and that for EEA traffic consent choices should be passed using consent parameters including:
ad_storage;
analytics_storage;
ad_user_data;
ad_personalization.
Users may accept, refuse or customize non-essential cookies and advertising technologies.
Refusing consent does not prevent access to the website’s core functionality.
Where consent is granted, cookies and personal data may be used for:
personalized advertising;
non-personalized advertising;
analytics and measurement;
conversion tracking;
remarketing and advertising performance optimization.
You can change or withdraw your cookie preferences at any time through the cookie settings link available on our website.
8. How Google may process data
Where we use Google advertising, analytics or tag services, and where you provide the relevant consent, Google may receive and process certain personal data, cookie data, device information, online identifiers, browser information and interaction data for purposes including:
ad delivery;
conversion measurement;
fraud prevention;
reporting;
analytics;
remarketing;
ads personalization,
depending on your consent choices and our configuration.
Google and its partners may act as independent controllers for certain data processing activities carried out through their advertising and analytics services, in accordance with Google’s own privacy policies and terms.
For more information about how Google uses business data, please see:
https://business.safety.google/privacy/
9. Sharing of personal data
We may share personal data with:
affiliated companies within the TheICircle group;
hosts, students, applicants or counterparties, where necessary to provide the requested accommodation or matching service;
service providers supporting CRM, communications, payments, document processing, cloud hosting, analytics, advertising, security, identity verification and customer support;
professional advisers, auditors, insurers and legal counsel;
regulatory bodies, courts, law enforcement authorities or tax authorities, where legally required;
third-party advertising and analytics providers, including Google, where this is permitted by law and based on the relevant legal basis, including consent where required.
We do not sell personal data in the ordinary meaning of selling customer data for money. However, some privacy laws may interpret certain advertising or analytics disclosures as “sharing” for advertising-related purposes.
10. International data transfers
Because TheICircle operates internationally, personal data may be processed in countries outside your country of residence, including the United Kingdom, the European Union, the United States and other jurisdictions where our service providers operate.
Where required by law, we implement appropriate safeguards for international data transfers, such as contractual protections, adequacy mechanisms or other lawful transfer tools.
11. Data retention
We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide services, comply with legal obligations, resolve disputes, enforce agreements and maintain business records.
Retention periods may vary depending on the type of data, the service involved, legal requirements and operational necessity.
Cookie consent records and related preferences may also be retained as necessary to demonstrate compliance.
12. Your rights
Depending on your jurisdiction, you may have the right to:
access your personal data;
correct inaccurate data;
request deletion of your data;
restrict or object to certain processing;
withdraw consent at any time;
request portability of certain data;
lodge a complaint with a competent data protection authority.
To exercise your rights, contact us at:
13. Minors
Our services are not intended for children under the age at which they can lawfully provide consent under applicable law without parental or guardian involvement.
Where required, we may request parental or legal guardian consent before collecting or using a minor’s personal data.
14. Security
We use reasonable technical, organizational and administrative measures designed to protect personal data against unauthorized access, loss, misuse, alteration or disclosure.
However, no online transmission or storage system can be guaranteed to be fully secure.
15. Third-party websites and services
Our website may contain links to third-party services, including payment providers, social platforms, external forms, maps or partner websites.
Those third parties operate under their own privacy policies and terms, and we are not responsible for their practices.
16. Updates to this Privacy Policy
We may update this Privacy Policy from time to time to reflect legal, technical, operational or business changes.
The most current version will be published on our website with the updated effective date.