Privacy Notice
Last updated 18 October 2026
1. The short version
We hold the names and mobile numbers of the people you trust most. We treat that seriously.
We do not sell your information. We do not advertise to you. We do not track you around the internet. We do not listen to or record your calls, and we do not know what is said on them, because we never have it. The one exception is a voicemail a caller chooses to leave, which we email straight to the account holder without listening to it, and do not keep.
We keep what we need to ring the right people when your number is called, to bill you, to show you what happened, and to meet the rules we must follow as a communications provider. That is all.
This notice explains it properly. If anything is unclear, ask us at hello@mycircall.com and we will explain it in plain English.
2. Who is responsible for your information
Eridan One Ltd, a company registered in England and Wales under company number 17304032, is the data controller for the MyCirCall service. That means we decide what information is collected and what happens to it, and we are answerable for it. Our registered office is 89 The Everglades, Hempstead, Gillingham, ME7 3PZ. We are registered with the Information Commission (the ICO), registration number ZC256674.
You can contact us about anything in this notice by email at hello@mycircall.com or by post at the address above.
3. If someone has added you to their CirCall
You may be reading this because you received a text inviting you to join someone's CirCall, and you want to know why we have your number. This section is for you.
Someone you know gave us your name and mobile number so that we could ring you if an important call comes in for them and they can't take it. They should have asked you first. Our terms require it.
What the invitation tells you. Before you accept, the invitation tells you who invited you, what MyCirCall is, the calls and texts you may get, that you won't pay anything or have a subscription, how to leave, and where to read this notice. You need to be 16 or over to join (section 12).
What we hold about you. Your name, your number, the relationship the account holder gave you (for example "Son" or "Neighbour"), which you can correct when you accept, confirmation that you accepted and verified your number, and a record of any call you took. We count the texts we send you but don't keep them.
What we do with it. We ring your phone when the account holder's MyCirCall Number is called. Your phone shows their MyCirCall Number, so you know it's an important call coming through them. If their plan includes it, we also text you after a call you were rung for, saying who answered or that nobody could, and when. These texts never include the caller's number. When you join, we offer you a contact card with their name and MyCirCall Number, so your phone can show who it is. Nothing else.
If you joined on a landline, you joined by an automated call, typing the PIN on your keypad. We never text a landline.
What we never do. We do not market to you, pass your number to anyone else, or use it for anything other than the service the account holder set up. You don't need an account with us, and you are never charged anything. (There is an optional member account if you'd like one: see section 4.)
Getting out. You are never rung until you have accepted an invitation and confirmed your own mobile number, so you can't be added without knowing. You can leave at any time, without anyone's permission:
- use the "Leave this CirCall" link we give you;
- reply LEAVE to any text we sent you about that CirCall;
- ring our automated leave line, which recognises your number, reads out the CirCalls you're in and asks you to confirm;
- use your member account, if you opened one; or
- contact us, or ask the account holder, and you will be removed.
When you leave, you are not rung or texted again, and we email the account holder to let them know. Your name and number stay in the account holder's Trusted Directory, their own list of contacts in MyCirCall, unless you ask us to remove them: there is a box to tick when you leave from your link or your member account, or you can ask us at any time (section 14). We then remove them and tell the account holder. (We can't change any contacts on the account holder's own phone.)
The rest of this notice, particularly your rights, applies to you as much as to account holders.
4. What we collect
If you hold an account
- Your details: name, email address, mobile number (and whether you have confirmed it), and a password that is stored only in scrambled (hashed) form. We can't see it, and neither could anyone who obtained our database.
- Your Trusted Directory and CirCall: the names, mobile numbers and relationships of the people you add, and whether each has accepted.
- Your MyCirCall Number, once one is allocated to you.
- Call records: the number that called, the date and time, how long the call lasted, whether it was answered, and who answered it.
- Texts to your MyCirCall Number, and your replies: we pass the words on to your mobile (or your reply on to the sender) and don't keep them. We keep who sent the latest texts and when for 7 days, so that your reply reaches the right person. The alert texts we send your CirCall are counted, not kept.
- The phones the app is signed in on: a code Apple or Google gives each phone, so we can send app notifications to it.
- Usage: minutes and alerts used against your plan's allowances, and the notices we sent you when an allowance was used up.
- Billing: your plan, your payment history, the receipts and other billing emails we sent you, and identifiers given to us by our payment provider. We never receive or store your full card number; a receipt shows only its last four digits.
- What you agreed to when you subscribed: your request to start straight away, the time, the wording you saw, the Contract Summary you were shown, the version of our terms, your plan and the price.
- Payment reminders: which reminders we sent, and when you used "Give me a few days". We never ask why, and we don't record a reason.
- The launch offer, if you take it: that you did, your plan and the price, and a scrambled form of your mobile number, made with a secret key we keep apart from the database, so the offer can be used only once per number. It isn't your number, but we can tell from it whether a number has had the offer, so it is still information about you; we delete it 12 months after the offer closes.
- Requests and complaints: what you tell us when you contact us, including requests to cancel or to transfer your number, and complaints.
- Notes about extra help, only if you agree: what helps you, such as large print, and never why. Separately, if you ask, who may deal with us for you and what they may do. We check with you once a year that they're still right. See section 5.
If you are in someone's CirCall
Your name, number, relationship, whether you accepted, and a record of any call you took. See section 3.
If you open the optional member account: your mobile number, the codes we text you to sign in (kept only in scrambled form, for 10 minutes), when you last signed in, and, if you say you're unavailable, until when. The account holders of the CirCalls you're in can see that you're unavailable and until when, but not why. You can choose there which CirCalls text you about calls; that choice is kept with your place in each CirCall. Texts with a code, and the one telling you your number has changed, still go when they're needed. To change your number there you must be signed in with a code to your current number; we then text a code to the new one, text your old number to say it has changed, and tell each of those account holders by email. You can delete the member account at any time; your place in each CirCall, and your text choices, are not affected.
Technical information
Our servers keep logs: the time of each request and the address it came from and, for calls and texts, which numbers were involved, when, and what happened. They never hold what was said on a call, what was typed on the keypad or what a text said. We use them to keep the service running securely and to work out what went wrong when something does.
If you call or text a MyCirCall Number
You may be a school, a surgery, a care home, a friend or anyone else ringing someone's MyCirCall Number. When you do:
- we record your number (or that it was hidden), the time, how long the call lasted and who answered, as part of the account holder's call history, and keep it for 12 months;
- the account holder sees your number in their call history, in an email if nobody could answer, and in a notification in the MyCirCall app;
- on some plans, the people in their CirCall who were rung get a text afterwards saying that a call came in and who answered, or that nobody could. It never includes your number.
If you hide your number, we never show it to anyone: they see "a hidden number".
If you text a MyCirCall Number, we pass your text on to the account holder's own mobile and don't keep what it said. We keep your number and the time for 7 days, so that if the account holder replies, the reply reaches you from the MyCirCall Number; then we delete them.
We do this because the account holder chose MyCirCall so that important calls and texts reach them or someone they trust (our legitimate interest, and theirs; see section 5). You can object, or ask what we hold about you, by contacting us (section 9).
If you leave a voicemail
On the Peace of Mind plan, if nobody can take your call, you can leave a message after the tone. Before the tone you hear that MyCirCall will record it and email it to the account holder, and where to find this notice. Recording starts at the tone, and you can hang up instead.
Please leave out medical details, about yourself or anyone else: say who you are and how to reach you, and the account holder can ring you back. If a message does include them, it is handled exactly as below, and nobody at MyCirCall listens to it.
We email the recording to the account holder as an audio file, then delete it from our telephony provider. Nobody at MyCirCall listens to it, and we keep no copy: our server passes it to the email without saving it. The account holder keeps the email, in their own mailbox, for as long as they choose. If the email cannot be sent at once, our telephony provider holds the recording while we try again, for up to 7 days, and then it is deleted. We keep a record that a voicemail was left (your number, the time and how long it was), as for any other call.
We do this because the account holder chose a plan with voicemail so that a caller nobody could answer can still leave a message for them (our legitimate interest, and theirs; see section 5).
What we do not collect: we do not record calls and we do not transcribe anything. A voicemail you choose to leave is the only recording, nobody at MyCirCall listens to it, and it is handled as described above. We do not know your location. We do not use your information to build a profile of you or to make automated decisions about you.
5. Why we use it, and our legal basis
Under UK data protection law we must have a lawful basis for using your information. Here is exactly what we rely on.
| What we use it for | Legal basis |
|---|---|
| Creating and running your account, and letting you sign in | Performing our contract with you |
| Ringing your phone and your CirCall when your number is called, and sending the text alerts your plan includes | Performing our contract with the account holder. For CirCall Members, our legitimate interest in delivering the service they agreed to take part in |
| Inviting a CirCall Member, verifying their number, and letting them leave | Our legitimate interest in making sure nobody is in a CirCall without knowing, or stays in one against their wishes |
| The optional member account: signing in, saying you're unavailable, your text choices, changing your number and leaving | Our legitimate interest in giving CirCall Members simple, secure control over taking part. We have written down why this is fair to members, including those aged 16 and 17 |
| Taking payment, managing your subscription, and payment reminders | Performing our contract with you |
| Telling support when you use "Give me a few days" | Our legitimate interest in looking after customers who may be finding things hard |
| Keeping a record of what you agreed to when you subscribed | Complying with our legal obligations, and our legitimate interest in being able to show what was agreed |
| Showing you your call history and usage, and telling you when an allowance is used up | Performing our contract with you, and complying with our obligations as a communications provider |
| Handling cancellations, refunds and number transfers | Performing our contract with you, and complying with our legal obligations |
| Handling complaints | Complying with our legal obligations as a communications provider |
| Recording calls to a MyCirCall Number, passing on texts sent to it, and showing callers' numbers to the account holder | Our legitimate interest, and the account holder's, in important calls and texts reaching the people they chose. We have written down why this is fair to callers (a legitimate interests assessment), and a hidden number is never shown. Call records are also what minutes and any charge for extra minutes are worked out from, which we must be able to show are right |
| Sending notifications to the MyCirCall app | Performing our contract with you |
| Recording a voicemail and emailing it to the account holder | Our legitimate interest, and the account holder's, in a message from a caller nobody could answer reaching them. Callers are told before the tone and asked to leave out medical details |
| Notes about extra help you need | Your explicit consent, given to the words we read out or send you, separately from anything else. You can withdraw it at any time, and saying no never changes your service or stops us helping you |
| Noting someone who may deal with us for you | Performing our contract with you, because you asked us to |
| Keeping the service secure, preventing fraud and misuse of the phone network | Our legitimate interest in protecting the service and its users |
| Keeping accounting, tax and billing records | Complying with our legal obligations |
| Emailing you about your service, for example a failed payment or a reminder to test your CirCall | Performing our contract with you |
Where we rely on legitimate interests, we have considered whether it is fair to you, and you can object (see section 9).
6. Who else sees it
We do not sell or rent personal information to anyone, ever. We do share it with a small number of suppliers who help us run the service, and only with what they need:
| Who | What for | What they get |
|---|---|---|
| Telnyx | Providing the phone numbers, connecting the calls and delivering the texts | The numbers involved in a call or text, the times, the words of our alerts, the words of texts sent to or from a MyCirCall Number, and voicemail recordings until we have emailed them. Telnyx also keeps its own records of the calls and texts it carries, as a telephone company must; we have asked it how long, and will add the answer here |
| Square | Taking payments and managing subscriptions | Your name, email and payment details, which go to them directly, not through us. Square's emails about your payments come to us, and we send you the receipts ourselves |
| IONOS, our hosting provider | Running the servers and database the service sits on | Whatever is stored on the server, held encrypted at rest in backups |
| SMTP2GO | Delivering the emails our server writes | Recipients' email addresses and the emails themselves, including a voicemail recording sent to an account holder. SMTP2GO doesn't keep what an email says; it keeps who it went to, when and its subject for up to 35 days |
| Apple and Google | Delivering notifications to the MyCirCall app on iPhone and Android | The code identifying the phone, and the notification's words, which can include a caller's number or a CirCall Member's name |
| Google (Gmail) | Our support mailbox: emails to hello@mycircall.com reach us through a Google mailbox | What you write to us |
| Google (Google Drive) | Keeping a copy of our backups away from our own server | Encrypted backup files only. They are locked with a key that only we hold, so Google cannot read them |
These suppliers act on our instructions and cannot use your information for their own purposes.
We also share information when you ask us to, or when the rules require it:
- If you transfer your MyCirCall Number to another provider, we share what is needed to move it with that provider and with Telnyx.
- If you take a complaint to our independent dispute resolution scheme, we share what it needs to look into it.
- If the law requires it, for example a valid request from the police, a court order, or an obligation owed to Ofcom. We will not hand over more than we have to.
If our business were ever sold or transferred, information would pass to the new owner, who would be bound by this notice.
7. Where your information is kept
Our database and servers are in the United Kingdom, in IONOS's UK cloud.
Some of our suppliers are based outside the UK, so some information reaches them abroad:
- Telnyx: we have chosen Germany as the storage location for our telephony data, so call and message records held by them stay in the European Economic Area. Telnyx is a US-headquartered company and some administration of that data may take place from the United States.
- Square: payment information is processed in the United States.
- Apple and Google: app notifications pass through their services, which may be outside the UK.
- SMTP2GO: emails pass through its servers, which are in the United States, the European Union or Australia, depending on the account. It keeps no copy of what an email says.
- Google: the encrypted copies of our backups may be stored outside the UK. Google cannot read them: only we hold the key.
Where information leaves the UK, we rely on the safeguards permitted by UK data protection law: an adequacy decision covering the country concerned, or standard contractual clauses agreed with the supplier, so that it keeps essentially the same protection it has here.
8. How long we keep it
| What | How long |
|---|---|
| Your account, CirCall and Trusted Directory | While your account exists. Deleted when you delete your account. If your subscription ends but you keep your account, they are kept so you can come back. If you have had no subscription and haven't signed in for 12 months, we delete the account; we email you a month before, and signing in keeps it. |
| A CirCall Member's place in a CirCall: that they accepted, how they joined and confirmed their number | Until they leave or are removed, or the account holder's account is deleted |
| A former member's name and number in the account holder's Trusted Directory | They're part of the account holder's own contacts: kept until the account holder deletes them, the member asks us to remove them (section 3), or the account is deleted |
| An optional member account | Until you delete it, or after 12 months without being signed into. Your places in CirCalls aren't affected |
| Call records: who called, when, for how long and who answered; the details of voicemails and Test Drives | 12 months, then deleted. They are also the record behind the minutes used and any charge for extra minutes. Deleted sooner if the account is deleted. |
| Texts sent to a MyCirCall Number, and the replies | What a text said: not kept once it has been passed on. Who sent it and when: 7 days, so a reply can reach them, then deleted. A text we couldn't pass on is deleted after 7 days. |
| The phones the app is signed in on | Until you sign out on that phone or delete your account, or after 12 months without the app being opened |
| Payment reminders and "Give me a few days" records | 12 months after that bill is paid or the subscription ends, then deleted |
| Billing and payment records, including the receipts we sent | 6 years, because tax law requires it |
| What you agreed to when you subscribed | 6 years after the contract ends, as evidence of the contract, then deleted |
| Complaints and correspondence | 2 years after the complaint is closed, then deleted. Ofcom asks for at least 12 months; a complaint can go to our dispute resolution scheme up to a year after our final answer |
| The launch offer's scrambled number | 12 months after the offer closes, then deleted. That you had the offer, and its price, stay with your billing records |
| Voicemail recordings | Not kept by us. Deleted from our telephony provider as soon as the email has gone, or after 7 days if it can't be sent. The emailed copy is the account holder's. |
| Notes about extra help, and who may deal with us for you | Until you ask us to remove them, or the account is deleted. We check with you once a year that they're still right. |
| Our record of a security incident or data breach | 6 years after it is closed, then deleted. It describes what happened without naming anyone, so we can show the ICO and Ofcom what we did |
| Encrypted backups | 30 days, then destroyed |
| Server logs | 90 days |
When we delete something it is removed from our live systems straight away, and disappears from our backups as those backups age out within 30 days.
9. Your rights
Whether you hold an account or are simply in someone's CirCall, you have the right to:
- see what we hold about you, and get a copy of it;
- correct anything that is wrong;
- have it deleted, where we don't need to keep it;
- object to us using it where we rely on legitimate interests;
- restrict what we do with it while a concern is being looked into;
- take it with you, in a machine-readable form; and
- withdraw consent at any time, where we relied on it.
To use any of these, contact us (section 2). We will respond within one month. It is free, and we may ask you to confirm who you are so that we do not give your information to somebody else.
Deleting your account. You can do this yourself, at any time, from your account. It happens straight away. It deletes your CirCall, your Trusted Directory, and your call and message history, and your name, email address and mobile number are deleted or anonymised.
We delete or anonymise your account information in line with this notice, except information we need to keep for legal, regulatory, fraud-prevention, security or accounting purposes, such as billing records (6 years) and the record of what you agreed to when you subscribed. Section 8 lists what is kept and for how long. If you'd rather we did it for you, contact us.
10. Cookies and tracking
We do not use tracking cookies, advertising cookies or analytics of any kind. There is no cookie banner on this site because there is nothing to consent to.
When you sign in to your account, your browser stores a sign-in token so that you stay signed in as you move between pages. It is not a cookie, it is not shared with anyone, and it is removed when you sign out.
Our pages load nothing from other companies, with one exception: when you pay, the card box is Square's own, loaded from Square, and what you type into it goes straight to Square.
11. How we protect it
- Traffic to and from the service is encrypted in transit.
- Passwords are stored hashed, never in a readable form.
- Backups are encrypted before they leave the server.
- Access to the live database is limited to those who need it to run the service.
- We never hold full card numbers. Our payment provider does.
No service can promise perfect security. If a breach ever affected your information, we would report it to the ICO within 72 hours of finding out, as the Privacy and Electronic Communications Regulations require of a communications service, whatever the risk. And we would tell you directly, without undue delay, if it was likely to affect your information or your privacy: what happened, which of your information, what it could mean for you, what we have done, and what you can do.
12. Children and young people
MyCirCall accounts are for adults aged 18 or over, and we do not knowingly collect information about children as account holders.
People aged 16 or over can be in someone's CirCall, and can use the optional member account. As they join, each member confirms they're 16 or over: it's one of the things they agree to on the join page, and a landline hears it before typing the PIN. We don't ask for proof of age.
We use members' information only to run the service, as this notice explains. We never use it for advertising or marketing, we don't build profiles of anyone, and we don't track where anyone is. A member can leave a CirCall whenever they want, without anyone's permission, and can choose their texts and say when they're unavailable in the member account. We have assessed how the ICO's Children's code applies to members aged 16 and 17.
Nobody under 16 can be in a CirCall. If we learn that someone under 16 has joined, we take them out, tell the account holder, and delete their name and number, from the account holder's contacts too. If you think a child is in a CirCall, tell us at hello@mycircall.com.
13. Changes to this notice
If we change how we use personal information, we will update this notice and change the date at the top. If a change matters to you, we will tell you by email rather than leaving you to notice.
14. Contacting us, and complaining
For anything about your information, contact us (section 2). Our Customer Complaints Code, at mycircall.com/complaints, explains how we handle complaints.
If you are not happy with how we have handled your information, you can complain to the UK regulator:
The Information Commission (the ICO) Wycliffe House, Water Lane, Wilmslow, Cheshire SK9 5AF Helpline: 0303 123 1113 ico.org.uk
We would rather you came to us first, so we get the chance to put it right.
15. If you registered to hear when MyCirCall goes live
Before MyCirCall opened, our website let you register your interest ("Stay in the loop"). This section covers only the details you gave us then.
What we collect: your name and email address; what you'd use MyCirCall for, and anything you chose to tell us; and when you registered and when you confirmed your email. We don't ask for a card, a phone number or an address.
What we do with them: we email you to confirm your address, and then once more when MyCirCall goes live. We count, in total, why people are interested, so we know who MyCirCall is helping; nobody outside Eridan One Ltd sees your answer. We won't send you anything else, and we never sell or share your details for anyone else's marketing.
Why we're allowed to: because you asked us to. You ticked the box and confirmed your email: that's your consent, and you can withdraw it at any time.
Who else handles them: only the companies that run our servers and send our email (IONOS and SMTP2GO, section 6), and only so they can do that job for us.
How long we keep them: if you never confirm your email, your registration is deleted after 30 days. Once confirmed, we keep your details until we've sent the email saying MyCirCall is live, and delete them within 3 months after that, unless you remove yourself sooner.
Removing yourself: every email we send has a Remove me link. It deletes your registration straight away. You can also email hello@mycircall.com to see, correct or delete the details we hold. Your other rights are in section 9.