1. Introduction

COOLEYS CIRCLE LLC. ("we," "us," or "our") is a referral and membership network dedicated to connecting members with trusted, vetted businesses — local, online, and national. We take your privacy seriously. This Privacy Policy explains how we collect, use, share, and protect your personal information when you use our website, membership platform, and services. By becoming a member, using our website, or interacting with our platform, you agree to the practices described in this Privacy Policy.
 

2. Information We Collect

We may collect the following types of information:
 

a. Information You Provide
 

• Full name, email address, phone number, and mailing address

• Account login credentials

• Payment or billing information (processed securely through third-party processors)

• Business information (for Merchant members)

• Communications you send us (emails, form submissions, messages)
   

b. Information Collected Automatically
 

• Browser type, IP address, and device information

• Pages visited, links clicked, and time spent on our site

• Cookies and similar tracking technologies
   

c. Information from Third Parties
 

• Referral information when you're invited by a Community Connector or Member

• Merchant or business profile data submitted during the onboarding process
   

3. How We Use Your Information
 

We use your information to:
 

• Create and manage your Cooley's Circle membership account

• Connect you with trusted, vetted businesses and promotions

• Deliver member-exclusive coupons and merchant offers

• Send transactional and marketing communications (SMS, email, or direct message) based on your preferences

• Onboard and manage Merchant members and their promotions

• Support Community Connectors in growing the network

• Improve our platform, services, and user experience

• Comply with legal obligations
   

4. Coupon & Promotion Services
 

To redeem merchant promotions or coupons, members must be logged into their Cooley's Circle account. Coupon delivery is tied to your verified membership status. We do not share your personal redemption data with merchants beyond what is necessary to honor a promotion.
 

5. How We Share Your Information
 

We do not sell your personal information. We may share your information:
 

• With Vetted Merchants: Limited contact or membership data may be shared to facilitate a referral or promotion you've opted into.
   

• With Service Providers: Third-party tools we use to operate our platform (e.g., CRM, email, SMS, payment processing).
   

• With Community Connectors: Only as necessary to manage the referral relationship.
   

• For Legal Compliance: When required by law, court order, or to protect our legal rights.
   

• Business Transfers: In the event of a merger, acquisition, or sale of COOLEYS CIRCLE LLC assets.

Important Exception for SMS Data: Notwithstanding any of the above, SMS/text messaging opt-in data and consent are never shared with third parties, affiliates, or merchants for marketing or promotional purposes.
This data is treated separately from all other membership data described in this section. See Section 6 (SMS Communications) for full details.
 

6. SMS Communications
 

By joining COOLEYS CIRCLE LLC and providing your mobile phone number, you consent to receive SMS text messages from Cooley's Circle. These messages may include membership updates and announcements, account and transactional notifications, merchant offers, coupons, promotions, and customer care communications.
 

Message frequency may vary. Message and data rates may apply.
 

You may opt out of SMS communications at any time by replying STOP. For assistance, reply HELP or contact us directly at Tracey@cooleyscircle.com.
 

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. Information sharing to subcontractors in support services, such as customer service is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
 

7. Cookies and Tracking Technologies
 

Our website may use cookies, analytics tools, and similar technologies to improve user experience, monitor website performance, analyze visitor activity, and support our services. These technologies may collect information such as browser type, device information, pages visited, time spent on the website, and referring websites. You may adjust your browser settings to refuse cookies; however, some website functionality may be affected.
 

8. Data Retention
 

We retain your information for as long as your account is active or as needed to provide services. You may request deletion of your data at any time by contacting us at help@cooleyscircle.com.
 

9. Your Rights

Depending on your location, you may have the right to:

• Access the personal data we hold about you

• Correct inaccurate information

• Request deletion of your data

• Opt out of marketing communications

• Lodge a complaint with a data protection authority
   

10. Security
 

We implement reasonable administrative, technical, and physical safeguards to protect your information. However, no method of transmission over the internet is 100% secure.
 

11. Children's Privacy
 

COOLEYS CIRCLE LLC is not intended for individuals under 18 years of age. We do not knowingly collect data from children.
 

12. Changes to This Policy
 

We may update this Privacy Policy from time to time. We'll notify members of material changes via email or a notice on our platform. Continued use of our services after changes constitutes acceptance.
 

13. Contact Us
 

COOLEYS CIRCLE LLC Tracey Cooley, Founder Oswego, IL 
Tracey@cooleyscircle.com (630) 338-5394