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PRIVACY POLICY

Last updated: February 10, 2026

 

This Privacy Notice for Members Development Company, LLC (doing business as Circuit) (“we,” “us,” or “our”) describes how and why we may access, collect, store, use, and/or share (“process”) your personal information when you use our services (“Services”), including when you:

 

  • Visit our website at http://www.circuitcu.com or any website of ours that links to this Privacy Notice

  • Engage with us in other related ways, including any marketing or events


Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have questions or concerns, contact us at kristenj@circuitcu.com.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice. You can find more details by reviewing the full policy below.

 

  • What personal information do we process? We may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.

 

  • Do we process sensitive personal information? No, we do not process sensitive personal information.

 

  • Do we collect information from third parties? No, we do not collect information from third parties.

 

  • How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with the law.

 

  • When and with whom do we share personal information? We may share information in specific situations, such as business transfers.

 

  • How do we keep your information safe? We use organizational and technical security measures to protect your personal information, but no system is 100% secure.

 

  • What are your rights? Depending on where you live, you may have rights regarding your personal information.

 

  • How do you exercise your rights? You can submit a data subject access request or contact us directly.

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us


In short: We collect personal information that you voluntarily provide to us.

 

This includes information you provide when you express interest in our Services, participate in activities on the Services, or contact us.

 

Personal information may include:

 

  • Names

  • Phone numbers

  • Email addresses

  • Job titles

 

Sensitive information: We do not process sensitive personal information.
 

Information automatically collected


In short: Some information is collected automatically when you use our Services.

 

This may include:

 

  • IP address

  • Browser and device characteristics

  • Operating system

  • Language preferences

  • Referring URLs

  • Device name

  • Country and general location

  • Usage data and activity on our Services

 

We also collect information through cookies and similar technologies.

 

Automatically collected information includes:

 

  • Log and usage data

  • Device data

  • Location data

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2. HOW DO WE PROCESS YOUR INFORMATION?

In short: We process your information to provide, improve, and administer our Services, communicate with you, prevent fraud, and comply with legal obligations.

 

We may process personal information to:

 

  • Administer promotions, contests, or giveaways

  • Evaluate and improve our Services and marketing efforts

  • Determine the effectiveness of campaigns

  • Comply with legal obligations

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In short: We may share information in specific situations.

 

These include:

 

  • Business transfers, such as mergers, acquisitions, or asset sales

 

We do not sell or share personal information for commercial purposes.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In short: Yes, we may use cookies and similar technologies.

 

These technologies help us:

 

  • Maintain site functionality

  • Improve performance

  • Analyze usage

  • Deliver relevant advertising (where applicable)


We may use Google Analytics to analyze how users interact with our Services. You can opt out of Google Analytics tracking at: https://tools.google.com/dlpage/gaoptout

5. HOW LONG DO WE KEEP YOUR INFORMATION?

In short: We keep your information only as long as necessary for the purposes described in this Privacy Notice or as required by law.

 

When we no longer need your information, we will delete or anonymize it where possible.

6. HOW DO WE KEEP YOUR INFORMATION SAFE?

In short: We use reasonable technical and organizational security measures to protect your personal information.

 

However, no system can be guaranteed to be completely secure, and transmission of data is at your own risk.

7. DO WE COLLECT INFORMATION FROM MINORS?

In short: No. We do not knowingly collect data from or market to children under 18 years of age.


If we learn that personal information from a minor has been collected, we will delete it promptly. Contact us at kristenj@circuitcu.com if you believe this has occurred.

8. WHAT ARE YOUR PRIVACY RIGHTS?

In short: You may review, change, or request deletion of your personal information depending on your location.

 

Your rights may include:

 

  • Access to your personal data

  • Correction of inaccurate data

  • Deletion of personal data

  • Obtaining a copy of your data

  • Opting out of certain processing

 

To exercise your rights, submit a data subject access request or contact us directly.

9. CONTROLS FOR DO-NOT-TRACK FEATURES

We do not currently respond to Do-Not-Track browser signals due to the lack of an industry standard.

10. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

Residents of certain U.S. states may have additional rights under state privacy laws, including access, correction, deletion, and opt-out rights.

 

We do not sell or share personal information and have not done so in the past 12 months.

11. DO WE MAKE UPDATES TO THIS NOTICE?

Yes. We may update this Privacy Notice as needed to comply with laws. Updates will be reflected by the “Last updated” date at the top of this policy.

12. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?

You may contact us at:

 

Members Development Company, LLC 1630 Welton Street PMB DVO13 Denver, CO 80202 United States


Email: kristenj@circuitcu.com

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Depending on your location, you may request access to, correction of, or deletion of your personal information by submitting a data subject access request or contacting us directly.

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