Data Protection Commissioner
Data Protection Commissioner

Registry Details for 'Circle Internet Financial Trading Company Limited t/a Circle'

Company Name: Circle Internet Financial Trading Company Limited t/a Circle
Ref Number: 14847/A
Reg Type: DC
Company Address: 8 Clanwilliam Square Grand Canal Quay Dublin 2 D02 PF75
Contact: Support@Circle.Com
Purpose: Circle Ireland provides customer experience, risk, and compliance support for Circle Internet Financial, Inc
('Circle US') and Circle UK Trading Limited ('Circle UK') - together referred to as 'Circle'. Circle UK provides consumer finance services to customers in the European Economic Area, while Circle US provides consumer finance services to customers in the United States. Circle Ireland provides consumer finance services to customers not located in the EEA or US.
Continuation Due Date: 13/10/2018
Description: Circle Ireland reviews identity, device, and geolocation data for customers, including the following:Name, address, date of birth, and tax identification numberTelephone, email address, residential and billing addressesPersonal identification documents such as licenses and/or passportsTransaction history and blockchain analysisIP address, device characteristics and browser configurationCurrent account numbersCredit/debit card tokens and last 4 digits of cardsConsumer information from third party credit or identity databasesSocial media searches and web presenceThe above information is collected in order to assist customers when they experience issues with the product, to prevent fraudulent transactions, and to conduct 'Know Your Customer' reviews and due diligence to meet regulatory anti-money laundering obligations.
Disclosees: Circle Ireland discloses EU customer data to Circle US and Circle UK throughout the normal course of business. In addition, customer data is provided to private risk and compliance vendors to assist with identity verification, fraud prevention, due diligence, and customer communications. Finally, Circle Ireland shares EU customer data with UK and EU regulatory authorities, law enforcement, and government officials via suspicious activity reports and responses to legal information requests. Circle US is certified under the EU-US Privacy Shield regime.
Transfers Abroad: Circle Ireland transfers customer data to Circle US for assistance in performing customer support, risk reviews, and compliance investigations. Circle is a global firm that strives to provide 24 hour support Monday through Friday, and as such makes use of