Privacy Policy

1. Scope and Controller

1.1 Controller. SkiCircle is responsible for personal information under its control. You can contact SkiCircle's privacy team at hello at skicircle dot ca.

1.2 Other parties. Other users, payment providers, app stores, identity verification vendors, resorts, event partners, analytics providers, map providers, and other third parties may process information under their own privacy policies. Review their policies before using their services.

1.3 Privacy laws. SkiCircle designs its privacy program for Canadian private-sector privacy law, including PIPEDA where applicable, Quebec's private-sector privacy law as amended, and other applicable provincial, consumer, anti-spam, and civil laws.

2. Information We Collect

2.1 Account and profile information. We collect information you provide when creating or updating an account, such as name, username, display name, email address, phone number, password or authentication token, profile photo, city or region, language preference, age confirmation, pronouns if provided, social links if provided, and account settings.

2.2 Ski and snowboard preferences. We may collect ability level, terrain preferences, pace, resort preferences, equipment type, snow-sport interests, availability, trip goals, risk tolerance, accessibility preferences, and whether you are interested in resort, park, racing, touring, backcountry, social, family, or carpool features.

2.3 Location information. With your permission or through your settings, we may collect approximate location, precise GPS location, live location, resort check-ins, meeting points, routes, trip timestamps, distance from other users, device location signals, and location derived from IP address or app usage. Precise and live location features should be off until you enable them.

2.4 Circles, events, and carpool information. We collect Circle membership, event RSVPs, host details, meeting points, planned dates, routes, terrain descriptions, carpool offers, ride requests, seats, vehicle details you choose to share, pickup and drop-off points, cost-share amounts, cancellations, disputes, reviews, and related messages.

2.5 Messages and communications. We collect messages, attachments, reports, support requests, emails, push-notification tokens, SMS verification records, and communications with SkiCircle or other users through the Service. We may process messages for delivery, safety, moderation, legal compliance, abuse prevention, and support.

2.6 User Content. We collect photos, videos, reviews, condition reports, comments, route notes, profile prompts, public posts, event descriptions, usernames, and other content you submit or make available.

2.7 Contacts and invitations. If you choose to use friend-finding or invitation features, we may collect contacts you authorize us to access, such as names, phone numbers, email addresses, and social handles. We may use hashed or encrypted contact matching where practical. We do not invite contacts unless you direct us to do so or the feature clearly states the invitation flow.

2.8 Emergency contacts. If you add emergency contacts, safety contacts, or trusted contacts, we collect their name, relationship, contact details, and instructions you provide. You are responsible for having permission to provide their information.

2.9 Device, log, and usage information. We collect IP address, device identifiers, operating system, app version, browser type, mobile carrier, language, time zone, crash logs, diagnostics, pages viewed, features used, clicks, searches, referral URLs, authentication logs, security events, and approximate location derived from technical signals.

2.10 Cookies, SDKs, and similar technologies. We and our service providers may use cookies, pixels, local storage, mobile SDKs, and similar technologies for authentication, preferences, analytics, fraud prevention, performance, attribution, and marketing, subject to consent requirements and your choices.

2.11 Payment information. We collect transaction details, purchase history, subscription status, refund records, invoices, taxes, payment method identifiers, chargeback information, and fraud signals. Full payment-card data is processed by payment providers unless we expressly state otherwise.

2.12 Verification information. If identity or trust verification is used, we or our verification provider may collect phone number, email verification status, government-ID images or extracted data, selfie images, liveness checks, biometric templates or signals where separately disclosed, date of birth, fraud signals, and verification results.

2.13 Safety reports and investigations. We collect report details, reported content, reporter information, accused-user information, witness information, messages, trip details, carpool details, location records, photos, device data, payment data, moderation notes, and outcomes related to safety, fraud, harassment, copyright, privacy, or legal reports.

2.14 Customer support and surveys. We collect information you provide in support tickets, feedback, surveys, interviews, bug reports, feature requests, and other communications.

2.15 Information from third parties. We may receive information from app stores, payment providers, identity providers, analytics providers, marketing partners, social-login providers, other users, public sources, law enforcement, resorts, insurers, or safety partners where permitted by law.

3. Sensitive Information and Express Consent

3.1 Sensitive information. Some information may be sensitive because of its nature or context, including precise location, live location, identity documents, biometric information, safety reports, health or accessibility information, emergency contacts, incident records, payment fraud data, and private messages.

3.2 Express consent. Where required by law, including for sensitive information in Quebec, we will seek express consent before collecting, using, or disclosing sensitive information, unless an exception applies.

3.3 Withdrawal. You may withdraw consent where consent is the legal basis for processing, subject to legal or contractual restrictions and reasonable notice. Withdrawal may limit or prevent use of features that require the information.

4. Collection by Technological Means, Identification, Location, and Profiling

4.1 Notice. Before collecting personal information through technology that identifies, locates, or profiles you, we will provide notice of the use of that technology and the means available to activate or deactivate relevant functions where required by law.

4.2 Profiling. Profiling may include analyzing your preferences, location, activity, events, messages, reviews, and safety signals to recommend circles, users, resorts, carpools, content, safety prompts, or paid features.

4.3 Privacy defaults. Where required, privacy settings will be configured to the highest level of confidentiality by default, except for settings necessary to provide the requested Service.

4.4 Location controls. Precise location, live location sharing, and post-trip route visibility should require clear user action. You can control location permissions through app settings and device settings. Some core features may work with approximate location only.

5. How We Use Personal Information

5.1 Provide the Service. We use information to create accounts, authenticate users, operate profiles, match users, create Circles, deliver messages, coordinate events, coordinate carpools, process payments, provide support, show relevant content, and maintain user settings.

5.2 Safety and integrity. We use information to verify accounts, detect fake profiles, prevent harassment, investigate reports, moderate content, detect fraud, enforce rules, protect users, respond to emergencies, preserve evidence, and protect platform integrity.

5.3 Location features. We use location information to show nearby users, resorts, events, routes, meeting points, carpools, safety prompts, weather or map integrations, and location-sharing features you enable.

5.4 Payments and subscriptions. We use payment and transaction information to process purchases, subscriptions, refunds, taxes, invoices, chargebacks, fraud reviews, promotions, and accounting records.

5.5 Personalization. We use information to recommend ski partners, Circles, events, resorts, terrain types, carpool matches, content, notifications, and product features.

5.6 Communications. We use information to send service messages, safety alerts, account notices, verification codes, event reminders, carpool updates, support replies, policy notices, and marketing where permitted.

5.7 Analytics and improvement. We use information to understand feature use, diagnose errors, improve performance, conduct research, develop new features, train internal moderation and safety systems using permitted data, and measure marketing effectiveness.

5.8 Legal compliance. We use information to comply with privacy, consumer, tax, accounting, anti-spam, copyright, court, law-enforcement, and regulatory obligations, and to establish, exercise, or defend legal rights.

5.9 De-identified and aggregated information. We may create de-identified or aggregated information and use it for analytics, safety, product development, business reporting, and research. We will take reasonable measures to prevent re-identification where required by law.

6. Matching, Recommendations, Moderation, and Automated Features

6.1 Recommendations. SkiCircle may use algorithms to recommend users, Circles, events, resorts, carpools, content, safety prompts, and paid features based on profile information, location, preferences, activity, availability, and interactions.

6.2 Moderation. We may use automated tools and human review to detect spam, fraud, harassment, unsafe conduct, prohibited content, and policy violations. Automated tools may make mistakes.

6.3 Significant automated decisions. Unless expressly disclosed in a feature-specific notice, SkiCircle does not make decisions based solely on automated processing that produce legal effects or similarly significant effects. If we introduce such a decision, we will provide required notice, explain the principal factors, and offer access to correction and human review where required by law.

7. How We Share Personal Information

7.1 With other users. We share information you choose to make visible, such as profile details, photos, ability level, preferences, Circle participation, event RSVPs, carpool details, reviews, messages, and location information you enable. Other users may save, copy, photograph, or misuse information they can see, despite our rules.

7.2 With Hosts, drivers, and passengers. When you join a Circle, event, or carpool, we may share relevant information with the Host, driver, passengers, or participants, such as display name, profile photo, messages, meeting point, pickup point, cost share, timing, safety notes you choose to share, and cancellation details.

7.3 With service providers. We share information with providers that help us operate the Service, including hosting, cloud storage, analytics, security, customer support, payments, subscriptions, app stores, identity verification, SMS, email, push notifications, maps, crash reporting, fraud prevention, translation, and legal services. Providers must protect information and use it only for authorized purposes.

7.4 With safety and legal recipients. We may share information with law enforcement, courts, regulators, emergency responders, ski patrol, resorts, insurers, payment providers, or affected users where reasonably necessary or legally required to prevent harm, investigate incidents, respond to legal process, enforce rights, or protect users.

7.5 With business partners. If we offer co-branded events, promotions, resort integrations, affiliate links, or partner services, we will disclose what information is shared and seek consent where required.

7.6 Business transactions. We may disclose information in connection with a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or due diligence, subject to confidentiality and applicable law.

7.7 With consent. We may share information for other purposes with your consent or at your direction.

8. Information Other Users May See

Depending on your settings and feature use, other users may see your display name, profile photo, approximate location or resort area, ability level, preferred terrain, availability, mutual Circles, event RSVPs, reviews, content, message status, carpool details, shared pickup point, live location if enabled, and other information you choose to share. Use privacy settings carefully. Avoid sharing home address, workplace, government ID, financial information, medical details, or other sensitive information in public profiles or group chats.

9. Public Content and Search Visibility

9.1 Public and semi-public areas. Some areas may be public or visible to many users, including public Circle pages, event pages, reviews, condition reports, usernames, and profile snippets. We will indicate visibility where practical.

9.2 Search engines. If SkiCircle enables web-visible pages, public content may be indexed by search engines. Deleting content from SkiCircle may not remove copies already cached or saved by others.

9.3 Safety removals. We may hide, restrict, or remove public content that creates safety, privacy, legal, or platform-integrity concerns.

10. Payments and Financial Providers

10.1 Payment processing. Payment providers process payment-card and financial information under their own terms and privacy policies. SkiCircle receives transaction identifiers, purchase status, refund status, chargeback data, fraud signals, invoices, and limited payment details needed to operate the Service.

10.2 App stores. If you purchase through Apple or Google, those stores may control billing, cancellation, refunds, and tax invoices. SkiCircle receives limited purchase and subscription information needed to provide paid features.

11. Cookies, SDKs, Analytics, Advertising, and Similar Technologies

11.1 Use of technologies. We use cookies, pixels, SDKs, local storage, and similar technologies to keep you signed in, remember settings, secure the Service, analyze usage, diagnose errors, prevent fraud, attribute installs, measure campaigns, and personalize features.

11.2 Advertising and measurement. If we use advertising or measurement partners, they may collect or receive device identifiers, IP address, app events, approximate location, and interaction data, subject to consent requirements and your choices.

11.3 Choices. You can control cookies through browser settings, device advertising settings, operating-system permissions, consent banners, and in-app settings where available. Blocking technologies may affect features.

12. Marketing Communications and CASL

12.1 Service messages. We may send non-marketing messages about accounts, safety, payments, events, legal notices, security, and support.

12.2 Marketing messages. We will send commercial electronic messages only with consent or as otherwise permitted by Canadian anti-spam law. Marketing messages will identify SkiCircle and include an unsubscribe mechanism.

12.3 Unsubscribe. You can unsubscribe from marketing emails or texts using the provided mechanism. Service messages may continue where necessary to provide the Service or comply with law.

13. International Transfers and Service Providers

13.1 Locations. SkiCircle and its service providers may process and store information in Canada, the United States, the European Economic Area, the United Kingdom, or other locations identified in our provider list or feature-specific notices.

13.2 Cross-border risks. Information processed outside your province or country may be subject to foreign laws, courts, law enforcement, and government access requests.

13.3 Safeguards. Before communicating personal information outside Quebec or Canada where required, we will assess privacy factors and use contractual, technical, and organizational safeguards appropriate to the sensitivity and legal requirements.

14. Retention

14.1 Retention principles. We retain personal information only as long as reasonably necessary for the purposes described in this Privacy Policy, or as required or permitted by law. Retention periods depend on sensitivity, feature use, legal obligations, safety needs, fraud risk, accounting requirements, and user expectations.

14.2 Typical retention periods. Unless a longer period is required or justified, we expect to use the following retention approach: account and profile information for the life of the account; transaction, tax, accounting, and subscription records for up to seven years; safety reports and enforcement records for up to seven years or longer if legally necessary; messages while accounts remain active and for a reasonable period after deletion for safety, backup, and legal reasons; precise live-location records for the shorter period needed to provide the feature or investigate safety issues; backup copies for up to 90 days after deletion from active systems.

14.3 Deletion and anonymization. When information is no longer needed, we will delete, anonymize, aggregate, or securely archive it according to our retention schedule and legal obligations.

15. Security

15.1 Safeguards. We use administrative, technical, and physical safeguards designed to protect personal information, including access controls, encryption in transit, secure development practices, monitoring, provider due diligence, incident response procedures, and employee or contractor confidentiality obligations.

15.2 No perfect security. No app, website, system, message, or storage method is perfectly secure. You are responsible for using strong passwords, protecting devices, keeping software updated, and avoiding oversharing sensitive information.

16. Breach and Confidentiality Incident Response

16.1 Response. If we become aware of a breach of security safeguards or confidentiality incident, we will assess the risk, take reasonable steps to reduce harm, preserve relevant records, and notify affected individuals, regulators, and other organizations where required by law.

16.2 Risk factors. Our assessment may consider sensitivity, probability of misuse, bodily or psychological harm, humiliation, identity theft, financial loss, reputational harm, relationship effects, and risk created by location, safety, or identity data.

17. Your Rights and Choices

17.1 Access and correction. You may request access to personal information we hold about you and request correction of inaccurate or incomplete information, subject to legal exceptions.

17.2 Deletion. You may request deletion of your account or certain personal information. We may retain information where required or permitted for legal, safety, fraud-prevention, accounting, backup, dispute, or legitimate business purposes.

17.3 Consent withdrawal. You may withdraw consent where processing is based on consent, subject to legal or contractual restrictions and reasonable notice.

17.4 Portability. Where applicable law grants a data-portability right and the information is held in a structured, commonly used technological format, you may request a portable copy.

17.5 Quebec privacy rights. Quebec residents may have additional rights, including rights to request information about processing, access, correction, withdrawal of consent, de-indexing or cessation of dissemination in certain circumstances, data portability when in force, and information about automated decisions where applicable.

17.6 Marketing and location choices. You can manage marketing preferences, notification settings, cookie choices, device permissions, and location permissions through the app, browser, device, or unsubscribe links.

17.7 Verification. We may need to verify your identity before responding to a rights request. Authorized agents may be required to provide proof of authority.

17.8 Timing. We will respond to privacy requests within the period required by applicable law. If we deny a request, we will explain the reason where required and provide information about complaint options.

18. Location Privacy Choices

18.1 Precise location. You may choose whether to enable precise location. Some features, such as nearby matching, live meetup coordination, route sharing, and safety check-ins, may require location access.

18.2 Live sharing. Live location sharing should be time-limited and visible only to the people or Circle you choose. You should be able to stop live sharing through the app or device settings.

18.3 After-event visibility. After an event or carpool, we will limit ongoing visibility of exact meeting points, pickup points, and live location history, except where needed for user-selected history, safety investigations, legal compliance, or disputes.

18.4 Sensitive locations. Avoid sharing home addresses, workplaces, schools, private lodging, or other sensitive locations in public Circles or group chats.

19. Children and Minors

SkiCircle is intended for adults 18 and older. We do not knowingly collect personal information from minors. If we learn that a minor has created an account or provided personal information, we may deactivate the account and delete information as required by law. Contact hello at skicircle dot ca if you believe a minor has provided personal information.

20. Biometric Information and Identity Verification

20.1 Default position. SkiCircle should not collect biometric information unless a verification feature expressly states that biometric processing is used and you provide separate express consent.

20.2 Vendor processing. If selfie matching, liveness detection, face geometry, or similar technology is used, the verification vendor may process biometric information under its own privacy notice and data-processing terms. SkiCircle will identify the vendor, purpose, retention period, and choices before collection where required.

20.3 Quebec requirements. Before deploying a biometric database or identity-verification process involving biometric characteristics for Quebec users, SkiCircle must complete required notices, consent steps, security measures, and regulatory filings where applicable.

20.4 Alternatives. Where required by law or appropriate for fairness, SkiCircle will provide a reasonable non-biometric verification alternative, subject to fraud-prevention and safety needs.

21. Law Enforcement, Safety, and Emergency Requests

21.1 Legal requests. We may disclose information in response to subpoenas, warrants, court orders, production orders, regulator requests, or other valid legal process.

21.2 Emergency and safety requests. We may disclose information without delay where we reasonably believe disclosure is necessary to prevent or respond to serious harm, locate a missing person, address a ski or road emergency, investigate abuse, protect users, or protect the public, subject to applicable law.

21.3 User notice. We may notify users of legal requests where permitted and appropriate. We may delay or withhold notice where prohibited by law, where notice would create safety risk, or where notice would compromise an investigation.

22. Business Transfers

If SkiCircle is involved in a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, or similar transaction, personal information may be disclosed to transaction parties and transferred as part of the transaction, subject to confidentiality, privacy safeguards, and applicable law.

23. Changes to This Privacy Policy

23.1 Updates. We may update this Privacy Policy to reflect changes in our practices, features, providers, legal obligations, or business. We will update the effective date and provide notice where required by law.

23.2 Material changes. If a change materially affects how we handle sensitive information, location information, verification information, safety reports, marketing, or disclosures, we will seek consent or provide advance notice where required by law.

24. French Version and Quebec Residents

For Quebec users, SkiCircle will provide a French version of this Privacy Policy and related privacy notices where required by law. If you expressly choose English after receiving the French version where required, we may communicate with you in English. Mandatory language and privacy rights remain unaffected.

25. Complaints

You may contact SkiCircle's privacy team at hello at skicircle dot ca with questions or complaints. We will investigate and respond as required by law. You may also contact the Office of the Privacy Commissioner of Canada, the Commission d'acces a l'information du Quebec, or another applicable regulator, depending on your location and the nature of the complaint.

26. Contact

Company name: SkiCircle

Email: hello at skicircle dot ca