Last Updated: May 27, 2025
CircleUp LLC (“CircleUp”) is an educational performing arts management and communications platform for performing arts educators and their students, parents/guardians, staff, donors, patrons, and volunteers. It is used by non-profit performing arts organizations, K-12 institutions, and universities that educate students in the performing arts (“Organization”). Each Organization relies on CircleUp’s platform (the “Platform”) to aid in their education efforts.
CircleUp understands that privacy is extremely important to users of the Platform and each Organization that registers with the Platform, and the students, their parents and other users whose information CircleUp may access on behalf of your Organization.
In this Privacy Policy, “Personal Data” means any information about an identifiable individual or information that can be used to identify an individual, and includes “personal data” as that term is defined under the General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”). This Privacy Policy explains how CircleUp collects, processes, uses and discloses information from you and other users who access or use the Platform, including our treatment of Personal Data. This includes Personal Data (i) provided to CircleUp as a service provider by your Organization pursuant to the CircleUp Agreement and/or a separate written agreement between CircleUp and your Organization (in either case, the “Agreement”); (ii) collected by CircleUp as a service provider at the direction of your Organization; or (iii) provided by an individual account user. This Privacy Policy along with the Agreement and applicable laws govern CircleUp’s handling of Personal Data gathered in its capacity as a service provider.
If this Privacy Policy expressly contradicts the Agreement as to the data privacy and security, the Agreement will govern to the extent of the contradiction.
This Privacy Policy does not apply to websites, services or practices of companies that CircleUp does not own or control, even if they help CircleUp operate the Platform. Third party providers who help CircleUp operate the Platform must adhere to privacy and security obligations in a manner consistent with and at least as protective of Personal Data as are CircleUp’s policies and practices.
Please make sure that you read the CircleUp Terms of Use to understand additional terms and conditions that apply to the use of the Platform and website.
CircleUp collects three types of information: Personal Data that your Organization knowingly chooses to disclose that is collected on an individual basis; information you or your parent or legal guardian may knowingly enter on the Platform; and website usage information collected on an aggregate basis as you and others browse our website.
Information Your Organization May Provide to CircleUp
CircleUp may collect information (including Personal Data) when your Organization requests integration to access the Platform. CircleUp collects that information at the direction of your Organization, from your Organization’s systems of record. Information collected from Organization-provided data may include but is not limited to: name, ID number, phone number, email address, home/mailing address, group memberships, extracurricular activities, enrolled courses, classes, section, grade level, preferred communication language, emergency contact information, and family relationships.
Information You Provide to CircleUp
CircleUp receives and stores any information you knowingly enter on the Platform, including information you may be able to upload, import, or sync to the Platform from your mobile device (for example, photos from your phone).
This information may include but is not limited to Personal Data such as your name, phone numbers, email addresses, photographs and, in certain circumstances, your school and/or district, class, and group, attachments that may contain your voice and image. This information may be used to validate your account or to provide you with notifications via the Platform from a user associated with your Organization or any other information necessary for CircleUp to provide the Platform.
For certain Services, you may also choose to provide CircleUp with additional information about yourself in your user profile, such as your interests and abilities. All information you provide voluntarily may be made accessible to users in your Organization.
You may choose not to provide CircleUp with certain information, but then you may not be able to take advantage of many of the features of the Platform.
Information CircleUp Collects from You
CircleUp receives and stores certain types of information whenever you use the Platform. For example:
a. Website Activity Information: CircleUp monitors some of the actions you perform on the Platform. For example, if you read a post, CircleUp logs the fact that you read the post and at what time you did so.
b. Notification Activity Information: CircleUp monitors email delivery, text delivery, app downloads, and engagement through clicks in order to understand your interaction with the Platform and improve your experience with CircleUp. CircleUp may include clear gifs in the HTML-based emails CircleUp sends on behalf of your Organization in order to track which emails are being opened and which links are being clicked on by recipients.
c. Access Device and Browser Information: When you access the Platform from a computer, mobile phone or other device, CircleUp collects information from that device such as your browser type, operating system, unique device identifier, Internet Protocol (IP) address, the date and time of visits, and the time spent at CircleUp’s websites.
d. Cookie Information: CircleUp may send one or more cookies to be stored on your computer, mobile phone or other device in order to personalize your experience with CircleUp and make the Platform easier to use. A cookie is a small text file containing a string of alphanumeric characters that allows CircleUp to uniquely identify your browser and allows you to log in automatically whenever you return to CircleUp. CircleUp also uses cookies to identify and maintain your logged in status as well as enhance your navigation through the website. You can remove or block cookies using the technical settings of your browser though you may not be able to do so on certain browsers or mobile devices. Note that disabling cookies may impact your ability to use the Platform fully, so CircleUp recommends that you leave them enabled for the quality of your experience.
How is Children’s Personal Data Treated?
CircleUp complies fully with the Children’s Online Privacy Protection Act (“COPPA”).
Pursuant to COPPA, CircleUp collects consent from parents of children under 13 years of age in two primary ways: (1) your Organization's consent on behalf of parents in order to allow those under 13 years of age to use the Platform. (2) CircleUp may collect an under-13 user’s name (first and last name), date of birth, email address and/or telephone number in order to operate and provide the Platform from a parent directly in the Platform and consent will be provided by the parent at that time.
In order for an under-13 user to gain access to additional CircleUp features or products, CircleUp may employ one or more methods approved by the Federal Trade Commission for verifying parental consent.
If CircleUp learns that it had collected Personal Data from a child under age 13 other than pursuant to the above, or if CircleUp learns that a child under 13 has provided it Personal Data beyond what was requested from them, CircleUp will delete that information as quickly as possible after it has been notified internally or by impacted customers.
If you have questions about modifying or deleting Personal Data of a student on CircleUp, please contact your Organization directly.
Your privacy and your child’s privacy is extremely important to CircleUp. CircleUp uses the Personal Data it receives about you to provide you with the Platform and also for purposes such as:
To Manage the Service
CircleUp uses the information it collects to provide the Platform and features to you and provide you with customer support. In addition, CircleUp uses the information it collects to analyze how you use the Platform and features so that it can measure and improve the Platform and features.
To Contact You
CircleUp may contact you with Platform-related announcements from time to time. This includes contacting you for any Organization related activities. CircleUp may include content you see on the Platform in the emails it sends to you. CircleUp may also contact you in order to notify you about important changes to the Platform.
To Provide Relevant Information To Your Organization
CircleUp uses the information it collects to report usage levels to your Organization. This allows your Organization to monitor how successful their communications are so that they can improve their use of the Platform.
And most importantly, authenticating your identity, protecting our users, and working toward making sure the Platform are safer and more secure.
Email and Text Message Communications
If CircleUp has your email address or phone number, it may send you administrative messages (such as updates, notifications, newsletters and other news) relating to the Platform or to respond to communications from you. CircleUp may also send you urgent messages when it is directed to do so by an Organization or government agency.
By maintaining a CircleUp account and/or not opting out of receiving information from CircleUp, you acknowledge and agree that you may receive e-mail or SMS text messages on your phone or mobile device from other CircleUp users, from CircleUp and/or its third-party service providers and other individuals or companies if you choose to use applicable services or products that they offer. Receiving these messages may cause you to incur usage charges or other fees or costs in accordance with your wireless or data service plan. Any and all such charges, fees or costs are your sole responsibility. You should consult with your wireless carrier to determine what rates, charges, fees or costs may apply. CircleUp may receive a confirmation when you open an email from us if your computer supports this type of program.
Communications of this type are also sent to under-13 users and the parental consent to use this service also covers these messages. If you no longer wish to receive administrative email messages from CircleUp, you may opt-out by following the unsubscribe link located at the bottom of each message or by contacting us at privacy@circleupapp.co.
To permanently cease receiving SMS text messages, please text @STOP in reply to any SMS message from that Organization.
If you are located in Canada, you may opt out of receiving marketing messages (including text messages and emails); however, you may still receive text message and email communications that are necessary for the Platform or otherwise exempt from anti-spam laws.
Mobile Application
When users use CircleUp’s mobile applications, it automatically collects the IP address, device ID, device type, and what operating system (OS) the user is running.
CircleUp collects users’ IP addresses whenever they use CircleUp’s mobile applications, which provides it with a coarse approximation of the user’s location at the city level in order for CircleUp to, for example:
CircleUp also may, with your express consent, request more specific location information in order to provide you with more relevant information (such as nearby classes or relevant groups that you may subscribe to). CircleUp will not store or track your device location on an ongoing basis or without your permission. CircleUp may also collect location-based information from users as part of providing the Platform, or in order to comply with applicable laws and regulations for the user’s jurisdiction.
If the under-13 user has signed up for the Platform through SMS and then downloaded CircleUp’s mobile application, CircleUp will have and may use the under-13 user’s phone number:
Push Notifications
CircleUp sends notices to you for various reasons directly relating to your use of the Platform or at the request of your Organization, for example when an organizer of your class or group has posted something new to your class or group, you are sent a message, or when CircleUp needs to inform you of something. If you no longer wish to receive such communications, you may turn them off at the device level for applicable services or contact your Organization. If you are a parent of an under-13 user, you always have the choice to no longer allow your child to receive such communications by contacting CircleUp at privacy@circleupapp.co.
CircleUp uses the data received from your Organization for the sole purpose of delivering products and services to your Organization. CircleUp does not rent, trade, sell or otherwise distribute your information to any third parties, and will only disclose information when allowed by the Family Educational Rights and Privacy Act (“FERPA”) and required: a) by applicable laws or government orders, such as a law enforcement or court order; b) to maintain and operate the Platform; c) to enforce or apply the CircleUp Terms of Use and other agreements; d) to protect the rights, property or safety of CircleUp, its employees, its users or others; or e) when authorized by your Organization.
How Does CircleUp Work with Third Party Service Providers?
CircleUp works with a number of third party service providers and contractors to maintain and operate the Platform. For example, but not limited to, CircleUp uses third party service providers:
Before CircleUp engages with a third party where CircleUp may share Personal Data, it ensures that their privacy policy is at least as protective of your Personal Data as is CircleUp’s.
CircleUp will not provide any Personal Data to any person, party or organization ineligible to receive student records or student record data and information protected by FERPA, federal regulation, state law or regulation, or who is otherwise prohibited from receiving Organization data.
CircleUp also may provide to its third-party partners aggregated information derived from automatically collected information about how users, collectively, use the Platform. CircleUp may share this type of non-personally identifiable, aggregated statistical data so that its partners also understand how often people use their services as well as CircleUp’s.
No Advertising
CircleUp does not use student or user records or data collected for purposes of targeted advertising, and no student profile is built by CircleUp for reasons other than for the Organization’s purposes.
Your Organization or its users may post links within CircleUp to external websites for which CircleUp has no control. Before interacting with those third-party websites and their owners’ services or features, CircleUp recommends you familiarize yourself with their owners’ privacy policies and practices as CircleUp cannot control the data practices of these third parties.
Corporate Restructuring
In the case of a corporate event such as a sale of assets, an acquisition, or a merger of CircleUp with another organization, CircleUp may transfer your Personal Data. However, CircleUp will provide you with notice and an opportunity to opt-out of the transfer of Personal Data.
With Your Consent
You will be notified when your Personal Data may be shared with agents or companies other than CircleUp, and you will be given the option to prevent the sharing of this information unless CircleUp determines that not disclosing this to you prior to your information being shared is necessary to comply with applicable laws or legal processes or CircleUp is prohibited by law or legal processes from informing you in advance.
What Can Other CircleUp Users See
You are responsible for any content you provide in connection with the Platform. CircleUp cannot control the actions of anyone with whom you or any other CircleUp users may choose to share information. Therefore, CircleUp cannot and does not guarantee that content you or any user posts on the Platform will not be viewed by unauthorized persons. Although CircleUp may allow its users to set privacy options that limit access to certain parts of the Platform, please be aware that no security measures are perfect or impenetrable and that CircleUp is not responsible for circumvention of any security measures contained on the Platform. CircleUp does not encourage you to make any Personal Data public other than what is necessary for you to use the Platform. You understand and acknowledge that, even after removal, copies of content may remain viewable in cached pages, archives and storage backups or if other users have received, copied or stored your content. CircleUp will make efforts to remove the content under our control that is not part of another user’s account.
Notwithstanding the foregoing, your Organization may choose to share some CircleUp posts and associated pictures on social websites, such as but not necessarily limited to Facebook, Reddit, TikTok, YouTube, X, etc. If done via an integration, CircleUp will require your Organization to confirm that it has prior permission before doing so. Sharing posts and pictures on social websites will make the posts and pictures viewable by users outside of CircleUp, and CircleUp’s Privacy Policy will no longer apply to those posts and pictures.
CircleUp complies with, or works with your Organization to jointly ensure compliance with, FERPA and all other applicable confidentiality and privacy laws and rules, and requires its employees, consultants, and subcontractors to similarly comply. Each CircleUp user plays an important role in securing their account.
CircleUp takes great measures in keeping your Personal Data safe and secure. CircleUp encrypts Personal Data during transfer and at rest. CircleUp stores and protects your account information on a secured server behind a firewall. CircleUp utilizes encryption/security software to safeguard the confidentiality of Personal Data it collects.
If CircleUp becomes aware of a data breach of its users’ Personal Data, CircleUp will comply with applicable law, the Agreement, and notify your Organization as well as the affected users if asked to do so by your Organization or as required by applicable laws.
In the event of a data breach, as that term is defined in law or by the Agreement, the goal is to provide notice to your Organization within 72 hours (or sooner if required by law or the Agreement) after CircleUp has confirmed the data breach.
If there are actions required on the part of your Organization related to the breach, CircleUp will provide detailed instructions and assist in remediation.
Managing Your Account
You may review, update and correct the information in your account by logging into CircleUp. You are able to adjust your notification settings within CircleUp so that you receive instant or digest notifications for app notifications, emails and texts, or you may opt out of CircleUp communications and receive no notifications at all. If you choose not to receive notifications from CircleUp this will not stop you from receiving urgent notifications.
Deleting Your Account
If you are a member of CircleUp Organization and cease to agree with the CircleUp Terms of Use and Privacy Policy at some point in the future or if you no longer desire the Platform, please contact your Organization directly to delete your account.
Please note that certain information may remain in CircleUp’s records, server logs and archives after deletion of your account. CircleUp retains this information for purposes such as diagnosing problems with the Platform, to comply with various states’ open records laws or similar contractual commitments to an Organization, and for auditing legal investigations. CircleUp reserves the right to delete this information in accordance with its standard business practices in effect from time to time. Information and other content you have provided, however, may remain visible elsewhere to the extent such content was copied or stored by other users.
If your or your child’s Personal Data changes, you no longer desire to use the Platform, or you would like to rescind permission for the Platform to further contact your child, you may review, correct, update, delete inaccuracies, request deletion of your child’s information, or amend it by logging into your account and making those changes or contacting us at privacy@circleupapp.co.
CircleUp is not a healthcare organization and is not certified as compliant with the Health Information Portability and Accountability Act (“HIPAA”).
CircleUp reserves the right to change, modify, add or remove portions of this Privacy Policy. CircleUp will notify Organization administrators in writing or via email of material changes to this Privacy Policy, including practices around new or additional data collection, or practices that may lessen the previously noted protections around student data privacy.
If you have any questions or would like further clarification about CircleUp or this Privacy Notice, please e-mail CircleUp at privacy@circleupapp.co.
If you have questions or concerns pertaining to your information, your registration, your account, or unsubscribing from CircleUp, please contact your Organization directly. Otherwise, if you have questions about this Privacy Policy or CircleUp, you may contact CircleUp at privacy@circleupapp.co.
You can also direct inquiries in writing to:
CircleUp LLC
9400 SW Beaverton Hillsdale Highway, Ste 250
Beaverton, OR 97005