Last updated: December 1, 2025
We know privacy is important to you. It is important to us too. We encourage you to read this Privacy Policy to understand the information we collect, how we use it, and the choices available to you.
This Privacy Policy explains how we, Joya Communications Inc. DBA Marco Polo ("Marco Polo," "us," or "we"), creators of the Marco Polo Circles product ("Marco Polo Circles" or "Circles") collect, process, and protect the information of people who use Circles or who visit Marco Polo Circles websites that link to this Privacy Policy, such as https://circles.marcopolo.me (the "Marco Polo Website"). We will refer to Marco Polo Circles and the Marco Polo Circles Website, as well as any other interactions we have with you in which we collect your information, whether online or offline, collectively as the "Service(s)."
By using the Services, you agree to this Privacy Policy and that we may process, transfer, and store your information in the United States, as discussed further below.
The information we collect about you depends on the Services you use, how you use them, and the information you provide to us.
We collect information in three main ways: (1) information you provide directly to us; (2) information we collect automatically through technology when you use the Services; and (3) information we collect from other sources.
When you use our Services, you may provide certain information to us. For example, we collect information directly from you when you purchase a product or subscription from us, register for or use a Marco Polo Circles account, participate in Circles surveys or research, or otherwise communicate and interact with us.
Some of the most common categories of information we collect directly from you include:
Contact and account information. Which may include name, address, telephone number, email address, and your Marco Polo Circles account information.
Demographic Information. In creating a Circles account, we ask you to provide information such as your age, gender, hobbies, and interests. This helps us successfully match people in Circles.
Financial and transactional information. When you pay for Circles (which is processed by our third-party payment service providers on our behalf), we may receive from such payment processors information like payment type, amount, billing address, and the last 4 digits of your financial account used to make the payment.
Customer service interaction information. This includes messages submitted to us through online forms, chats, or email, and summaries or voice or video recordings of interactions with our customer service personnel.
Information submitted in connection with reviews and surveys. If you submit a review of the Services and associate it with your name or if you submit responses to surveys we provide, we will collect and store your responses and information.
When you use our Services, we may automatically collect certain information. We use a variety of third-party technologies, including cookies and similar tools, to assist in collecting this information. Please refer to the "Online Analytics and Advertising" section below for further information.
Some of the information we automatically collect when you use our Services includes:
Information about your access to and use of the Services and our emails, such as your IP address, browser language, the state or country from which you accessed the Services, software and hardware attributes (including device and mobile IDs, operating system, and browser type), referring and exit URLs, the links you click and files you download, pages viewed and the order of those pages, the amount of time spent on particular pages, the terms you use in searches on, or to get to, our Services, wireless carrier, the date and time you accessed our Services or opened our emails, and other similar information.
Location information. We may collect or derive general location information (e.g., city/state) from your IP address.
We may also receive information about you from other sources, such as business partners, marketers, researchers, analysts, social network services, and other parties (such as other users that ship items to you or purchase a gift card for you) to help us supplement our records.
We may de-identify information we collect so the information cannot reasonably identify you or your device, or we may collect information that is already in de-identified form. Our use and disclosure of de-identified information is not subject to any restrictions under this Privacy Policy, and we may use and disclose it to others for any purpose, without limitation.
Our Services use various technologies such as cookies, beacons, tags and scripts (collectively referred to herein as "cookies") for web analytics, functionality, performance, and online advertising purposes. These technologies are used in analyzing trends, administering the Services, understanding how users use the Services, and in gathering demographic information about our user base as a whole.
Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the "Help" section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). Please note that by blocking, disabling, or managing any or all cookies, you may not have access to certain features or offerings of the Services.
Online analytics
We may use third-party analytics services on our Services (e.g., Google Analytics). These service providers may set and access their own cookies, pixel tags, and similar technologies on our Services and on third-party services to collect information that can be used to track users over time and across services. These analytics services help us understand how users arrive at and use our Services.
If you do not want Google Analytics to collect and use information about your use of our websites, then you can install an opt-out in your web browser. You also may opt-out from Google Analytics for Display Advertising or the Google Display Network by using Google's Ads Settings.
Online advertising
We provide basic contact information we collect (such as email addresses and phone numbers) in hashed form to service providers and partners, who may "match" this information in de-identified form to cookies, mobile ad identifiers, and other proprietary IDs, in order to provide you with more relevant ads when you visit other online services, or to provide advertising to other individuals that may want to use our Services.
Moreover, we strive to provide you with relevant, value-added content in our online advertisements. We work with online analytics and advertising partners to: (1) better understand the use of our Services so that we can improve our Services; and (2) deliver Marco Polo advertisements that are more tailored to you as you browse the web.
Our partners may also place cookies, pixel tags and similar technologies on many online services, including ours. They use these technologies to collect information about your activities on these services in order to deliver you more relevant advertising. For example, they may use the information they collect from their cookies on our Services to identify Marco Polo products and services you might be interested in and to recognize your device so they can show you relevant Marco Polo advertisements while you are using our Services and other services.
If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your devices to deliver tailored advertising, you may visit the Digital Advertising Alliance's Consumer Opt-Out link to opt out of receiving tailored advertising from companies that participate in those programs.
We may use the information we collect in the following ways:
To provide the services you have requested, such as completing a purchase or offering customer support.
To communicate with you, for example, keeping you posted on your purchases, updates about the Services, and changes to our terms, conditions, and policies.
For marketing and advertising purposes, including providing you with the latest product announcements, promotions, and offers.
To personalize your experience and customize the Services, such as delivering relevant content, saving preferences, and recommending products and features through our Services.
To improve our Services, including bug detection and error reporting, to understand how users interact with our Services and advertisements, improve usability and effectiveness of our Services, perform research and analytics, and to test and create new products, features, and services.
For our business operations, including maintaining your account, reviewing complaints and concerns, and for security, fraud prevention, and legal compliance, such as detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity.
Other purposes for which we seek your consent. We may also use your information for a specific purpose that we communicate to you. We will ask for your consent to process your information for such purpose in accordance with applicable legal requirements.
For the purposes discussed in this Privacy Policy, we may combine the information that we collect through the Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Policy.
Legal Bases for Processing. The laws in certain jurisdictions (such as those in the European Union and United Kingdom), require us to inform you of the "legal bases" on which we process your information. The legal bases for using your information as set out in this Privacy Policy are as follows:
Where we need to perform the contract we are about to enter into or have entered into with you for the Services (e.g., under our Terms of Service).
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Where we have your consent to process your information in a certain way.
Marco Polo may disclose your information in the following ways:
Affiliated entities. We may disclose information within Marco Polo to deliver the Services, operate our business, and enhance our Services and your customer experience.
Service providers. We use select third-party vendors (including those that utilize large language model and other artificial intelligence tools) to help us provide our Services and operate our business, and we may provide access to or disclose your information to these vendors. They provide a variety of services to us, including customer service, payment processing, data privacy management solution providers, marketing, in-app notifications, product design and development, data storage, security, fraud prevention, research, and legal services. These service providers are permitted to access and use your information for purposes of performing services for Marco Polo or to comply with applicable legal requirements.
Other Users. Consistent with our Terms of Service, we may disclose certain of your information to other users of Marco Polo Circles as part of the matching process.
Online advertising partners. As discussed in the "Online advertising" section above, we may disclose certain information about you to our online advertising partners to assist in our online advertising and measurement activities.
Publicly. If you choose to provide feedback or submit a review of the Services, such submissions may be published on the Services, in emails, television, and on social media platforms. Published reviews may identify your name and location, if provided. Do not submit any personal or sensitive information in connection with or in reviews that you do not want publicly published in these ways.
Protection of Marco Polo and others. We may disclose the information we collect about you if required to do so by law or in a good faith belief that such disclosure is reasonably necessary to: (a) comply with legal process (for example, a subpoena or court order); (b) enforce our terms of service or sale, this Privacy Policy, or other contracts with you, including investigation of potential violations; (c) respond to claims that any content violates the rights of third parties; or (d) protect the rights, property, or personal safety of Marco Polo or others.
Business transfers. As we continue to develop our business, we may engage in transactions with other companies regarding the purchase or sale of a business. We may disclose your information as part of, or in contemplation of, such transactions. If a portion or all of Marco Polo' assets are transferred to a third party in connection with such transactions, your information may be among the transferred assets.
Please note that Marco Polo operates its business from the United States, and processes the information collected under this Privacy Policy in the United States. The United States may have different privacy laws than those in your jurisdiction of residence. Marco Polo will process information in accordance with the protections in this Privacy Policy.
Our Services are intended for general audiences and are not directed at children. If we become aware that we have collected or processed data without legally valid parental consent from children under an age where such consent is required under applicable law, we will take reasonable steps to delete it as soon as possible.
The Services may contain links to third party websites and online services. This Privacy Policy does not apply to the practices of other websites and online services, and we are not responsible for the actions and privacy policies of the third parties that operate or interact with those other websites. Please see the applicable privacy policies for such other sites and services for information about their practices.
We are committed to protecting your information. We use a variety of technical, physical, and organizational security measures designed to protect against unauthorized access, alteration, disclosure, or destruction of information. However, no security measures are perfect or impenetrable. As such, we cannot guarantee the security of your information. Alert us immediately if you have any concerns about unauthorized use of your account.
We retain information for different periods of time depending on the purposes for which we collect and use it, as described in this Privacy Policy. We will delete or de-identify information when it is no longer needed to fulfill these purposes unless a longer retention period is required to comply with applicable laws. There may be technical or other operational reasons where we are unable to fully delete or de-identify your information. Where this is the case, we will take reasonable measures to prevent further processing of your information.
Consumer Data Rights. We provide you with the ability to exercise certain controls and choices regarding our collection, use, and disclosure of your information under applicable laws. Your legal rights to exercise such controls and choices vary based on the laws of your jurisdiction (i.e., residents of certain US states (currently including California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia) and residents of the EU, UK, and Canada) can exercise the following rights by contacting us at privacy@marcopolo.me.
If you have provided consent for us to use your information for a specific purpose, you may also request to withdraw that consent.
In addition:
California and Oregon residents can request information about the categories of information we collect, disclose or sell or share about you; California residents can request the sources of such information, the business or commercial purpose for collecting or selling or sharing your information; and the categories of third parties to whom we disclose information. Such information is also set forth in this Privacy Policy.
Oregon and Minnesota residents can request a list of the specific third parties, other than natural persons, to which we have disclosed information.
Residents of the EEA, UK, or Switzerland can lodge a complaint about our practices regarding your information with the supervisory authority of your country.
We may ask you to provide us with information necessary to reasonably verify your identity before responding to your request. We will consider all requests and provide our response within the time period required by applicable law. Please note, however, that certain information may be exempt from such requests. We will not discriminate against you or treat you differently for exercising your rights.
If you are a resident of Colorado, Connecticut, Delaware, Iowa, Indiana, Kentucky, Maryland, Minnesota, Montana, Oregon, Nebraska, New Hampshire, New Jersey, Rhode Island, Tennessee, Texas, or Virginia and we deny your information request, you have the right to appeal our denial. You can exercise this right by contacting us at the contact details provided at the bottom of this Privacy Policy. Your description must include your full name and the email address used for your account with us, along with a copy of the denial notice you received from us.
Targeted Advertising Opt Out Rights.
If you are a resident of one of the U.S. states listed above, you also have the right to opt out of our processing or "sharing" of your information for online targeted advertising purposes as well as from the "sale" of your information to third parties in exchange for valuable consideration. We do not "sell" your information in the traditional meaning of the term to third parties in exchange for money. However, our disclosure of hashed contact information to third parties such as social media platforms to assist in our advertising activities may be considered a "sale" or "sharing" under applicable law. To opt out of this activity, email us at privacy@marcopolo.me.
Our use of analytics or online advertising tools as described in the "Online advertising" section above may also result in the disclosure of your information to our third-party partners and that are subject to these opt out rights. You can opt out of these activities by clicking the "Your Privacy/Cookie Choices" link on our website footer. If you have a legally-recognized browser-based opt out mechanism installed on your device (e.g., Global Privacy Control), you will be automatically opted out of these activities.
Adjust your marketing and communication preferences:
Email marketing. In accordance with applicable legal requirements, we send you informational and transactional, and marketing emails, including regarding activities on the Service, like when you receive a Polo from one of your contacts. You may choose to unsubscribe from emails by clicking "Unsubscribe" at the bottom of the email. If you unsubscribe, we may still need to send you non-marketing emails about your account, our business dealings with you (e.g., emails regarding subscriptions you have with us), updates to our policies, or security notifications.
Text/SMS Marketing. Opt out of text (SMS/MMS) messages from us by following the instructions included in our messages, or by replying "STOP" to the last message received.
The information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations, including the United States, where the applicable data protection laws may differ from those in your country of residence. By using the Services, you acknowledge that these transfers will occur and that we take appropriate steps to transfer your information in accordance with this Privacy Policy and applicable law.
If you are a California resident, the California Consumer Privacy Act ("CCPA") requires us to provide you with the following additional information about: (1) the purpose for which we use each category of "personal information" (as defined in the CCPA) we collect; and (2) the categories of third parties to which we (a) disclose such personal information for a business purpose, (b) "share" personal information for "cross-context behavioral advertising," and/or (c) "sell" such personal information. Please see the following chart containing this information:
| Category of personal information | Purposes of use | Categories of 3rd parties to which Marco Polo discloses this personal information | Categories of 3rd parties to which Marco Polo "shares" and "sells" this Personal information for advertising/analytics |
|---|---|---|---|
| Contact information and Account information | Provide the Services; Communicate with you; Marketing and advertising; Personalize the Services; Improve the Services; Business Operations; With your consent | Affiliated entities; Service providers; Online advertising partners; Entities for legal purposes; Entities for business transactions | Online advertising partners (contact information only, in hashed form) |
| Financial information | Provide the Services; Communicate with you; Improve the Services; Business Operations; With your consent | Affiliated entities; Service providers; Entities for legal purposes; Entities for business transactions | We do not share/sell |
| Transaction history | Provide the Services; Marketing; Personalize the Services; Improve the Services; Business Operations; With your consent | Affiliated entities; Service providers; Entities for legal purposes; Entities for business transactions | We do not share/sell |
| Customer service information | Communicate with you; Improve the Services; Business Operations; With your consent | Affiliated entities; Service providers; Entities for legal purposes; Entities for business transactions | We do not share/sell |
| Your Content | Communicate with you; Personalize the Services; Improve the Services; Business Operations; With your consent | Affiliated entities; Service providers; Entities for legal purposes; Entities for business transactions | We do not share/sell |
| Demographic Information | Communicate with you; Marketing and advertising; Personalize the Services; Improve the Services; Business Operations; With your consent | Affiliated entities; Service providers; Online advertising partners; Entities for legal purposes; Entities for business transactions | We do not share/sell |
| Surveys and sweepstakes information | Communicate with you; Personalize the Services; Improve the Services; Business Operations; With your consent | Affiliated entities; Service providers; Entities for legal purposes; Entities for business transactions | We do not share/sell |
| Information collected through automated technologies | Provide the Services; Marketing and advertising; Personalize the Services; Improve the Services; Business Operations; Recognize a user across multiple touchpoints; With your consent | Affiliated entities; Service providers; Online advertising partners; Entities for legal purposes; Entities for business transactions | Online advertising partners |
For more information about each category, purpose of use, and the third parties to which we disclose or share information, please see the "Information we collect", "How we use your information," and "How we disclose your information" sections of our Privacy Policy.
Your Choices Regarding "Sale" and "Sharing"
As a California resident, you have the right to opt out of our processing or "sharing" of your information for online targeted advertising purposes as well as from the "sale" of your information to third parties in exchange for valuable consideration. We do not "sell" your information in the traditional meaning of the term to third parties in exchange for money. However, our disclosure of hashed contact information to third parties such as social media platforms to assist in our advertising activities may be considered a "sale" or "sharing" under California law. To opt out of this activity, email us at privacy@marcopolo.me.
Our use of analytics or online advertising tools as described in the "Online advertising" section above may also result in the disclosure of your information to our third-party partners and that are subject to these opt out rights. You can opt out of these activities by clicking the "Your Privacy/Cookie Choices" link on our website footer. If you have a legally-recognized browser-based opt out mechanism installed on your device (e.g., Global Privacy Control), you will be automatically opted out of these activities.
Other CCPA Rights
The CCPA also allows you to limit the use or disclosure of your "sensitive personal information" (as defined in the CCPA) if your sensitive personal information is used for certain purposes. Please note that we do not use or disclose sensitive personal information other than for business purposes for which you cannot opt out under the CCPA.
Please see the "Your Rights and Choices" section above for information about the additional rights you have with respect to your personal information under California law and how to exercise them. We will not discriminate against you for exercising these choices.
Retention of your personal information
Please see the "Retention of your information" section above.
Notice concerning Do Not Track
Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our websites for third-party purposes, and that is why we provide the variety of opt-out mechanisms listed above. Some web browsers offer users a "Do Not Track" privacy preference setting in the web browser. We do not currently recognize or respond to browser-initiated Do Not Track signals.
California "Shine the Light" Notice
The California "Shine the Light" law gives residents of California the right under certain circumstances to opt out of the disclosure of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes, or in the alternative, that we provide a cost-free means for consumers to opt out of any such disclosure. We do not currently disclose your personal information to third parties for their own direct marketing purposes. To opt out of activities that are considered "sales" or "sharing" under California law, please see the "Your Choices Regarding 'Sale' and 'Sharing'" section above.
From time to time we may change or update this Privacy Policy to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. You should review the Privacy Policy periodically, and you can know if the Privacy Policy has changed since the last time you reviewed it by checking the "Last Updated" date at the beginning of the document. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Privacy Policy. If we make material changes to the Policy, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective, in accordance with applicable legal requirements.
We welcome your comments or questions about this Policy. You may contact us at privacy@marcopolo.me.
2025 © Joya Communications Inc.
Last updated: December 1, 2025
We know privacy is important to you. It is important to us too. We encourage you to read this Privacy Policy to understand the information we collect, how we use it, and the choices available to you.
This Privacy Policy explains how we, Joya Communications Inc. DBA Marco Polo ("Marco Polo," "us," or "we"), creators of the Marco Polo Circles product ("Marco Polo Circles" or "Circles") collect, process, and protect the information of people who use Circles or who visit Marco Polo Circles websites that link to this Privacy Policy, such as https://circles.marcopolo.me (the "Marco Polo Website"). We will refer to Marco Polo Circles and the Marco Polo Circles Website, as well as any other interactions we have with you in which we collect your information, whether online or offline, collectively as the "Service(s)."
By using the Services, you agree to this Privacy Policy and that we may process, transfer, and store your information in the United States, as discussed further below.
The information we collect about you depends on the Services you use, how you use them, and the information you provide to us.
We collect information in three main ways: (1) information you provide directly to us; (2) information we collect automatically through technology when you use the Services; and (3) information we collect from other sources.
When you use our Services, you may provide certain information to us. For example, we collect information directly from you when you purchase a product or subscription from us, register for or use a Marco Polo Circles account, participate in Circles surveys or research, or otherwise communicate and interact with us.
Some of the most common categories of information we collect directly from you include:
Contact and account information. Which may include name, address, telephone number, email address, and your Marco Polo Circles account information.
Demographic Information. In creating a Circles account, we ask you to provide information such as your age, gender, hobbies, and interests. This helps us successfully match people in Circles.
Financial and transactional information. When you pay for Circles (which is processed by our third-party payment service providers on our behalf), we may receive from such payment processors information like payment type, amount, billing address, and the last 4 digits of your financial account used to make the payment.
Customer service interaction information. This includes messages submitted to us through online forms, chats, or email, and summaries or voice or video recordings of interactions with our customer service personnel.
Information submitted in connection with reviews and surveys. If you submit a review of the Services and associate it with your name or if you submit responses to surveys we provide, we will collect and store your responses and information.
When you use our Services, we may automatically collect certain information. We use a variety of third-party technologies, including cookies and similar tools, to assist in collecting this information. Please refer to the "Online Analytics and Advertising" section below for further information.
Some of the information we automatically collect when you use our Services includes:
Information about your access to and use of the Services and our emails, such as your IP address, browser language, the state or country from which you accessed the Services, software and hardware attributes (including device and mobile IDs, operating system, and browser type), referring and exit URLs, the links you click and files you download, pages viewed and the order of those pages, the amount of time spent on particular pages, the terms you use in searches on, or to get to, our Services, wireless carrier, the date and time you accessed our Services or opened our emails, and other similar information.
Location information. We may collect or derive general location information (e.g., city/state) from your IP address.
We may also receive information about you from other sources, such as business partners, marketers, researchers, analysts, social network services, and other parties (such as other users that ship items to you or purchase a gift card for you) to help us supplement our records.
We may de-identify information we collect so the information cannot reasonably identify you or your device, or we may collect information that is already in de-identified form. Our use and disclosure of de-identified information is not subject to any restrictions under this Privacy Policy, and we may use and disclose it to others for any purpose, without limitation.
Our Services use various technologies such as cookies, beacons, tags and scripts (collectively referred to herein as "cookies") for web analytics, functionality, performance, and online advertising purposes. These technologies are used in analyzing trends, administering the Services, understanding how users use the Services, and in gathering demographic information about our user base as a whole.
Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the "Help" section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). Please note that by blocking, disabling, or managing any or all cookies, you may not have access to certain features or offerings of the Services.
Online analytics
We may use third-party analytics services on our Services (e.g., Google Analytics). These service providers may set and access their own cookies, pixel tags, and similar technologies on our Services and on third-party services to collect information that can be used to track users over time and across services. These analytics services help us understand how users arrive at and use our Services.
If you do not want Google Analytics to collect and use information about your use of our websites, then you can install an opt-out in your web browser. You also may opt-out from Google Analytics for Display Advertising or the Google Display Network by using Google's Ads Settings.
Online advertising
We provide basic contact information we collect (such as email addresses and phone numbers) in hashed form to service providers and partners, who may "match" this information in de-identified form to cookies, mobile ad identifiers, and other proprietary IDs, in order to provide you with more relevant ads when you visit other online services, or to provide advertising to other individuals that may want to use our Services.
Moreover, we strive to provide you with relevant, value-added content in our online advertisements. We work with online analytics and advertising partners to: (1) better understand the use of our Services so that we can improve our Services; and (2) deliver Marco Polo advertisements that are more tailored to you as you browse the web.
Our partners may also place cookies, pixel tags and similar technologies on many online services, including ours. They use these technologies to collect information about your activities on these services in order to deliver you more relevant advertising. For example, they may use the information they collect from their cookies on our Services to identify Marco Polo products and services you might be interested in and to recognize your device so they can show you relevant Marco Polo advertisements while you are using our Services and other services.
If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your devices to deliver tailored advertising, you may visit the Digital Advertising Alliance's Consumer Opt-Out link to opt out of receiving tailored advertising from companies that participate in those programs.
We may use the information we collect in the following ways:
To provide the services you have requested, such as completing a purchase or offering customer support.
To communicate with you, for example, keeping you posted on your purchases, updates about the Services, and changes to our terms, conditions, and policies.
For marketing and advertising purposes, including providing you with the latest product announcements, promotions, and offers.
To personalize your experience and customize the Services, such as delivering relevant content, saving preferences, and recommending products and features through our Services.
To improve our Services, including bug detection and error reporting, to understand how users interact with our Services and advertisements, improve usability and effectiveness of our Services, perform research and analytics, and to test and create new products, features, and services.
For our business operations, including maintaining your account, reviewing complaints and concerns, and for security, fraud prevention, and legal compliance, such as detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity.
Other purposes for which we seek your consent. We may also use your information for a specific purpose that we communicate to you. We will ask for your consent to process your information for such purpose in accordance with applicable legal requirements.
For the purposes discussed in this Privacy Policy, we may combine the information that we collect through the Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Privacy Policy.
Legal Bases for Processing. The laws in certain jurisdictions (such as those in the European Union and United Kingdom), require us to inform you of the "legal bases" on which we process your information. The legal bases for using your information as set out in this Privacy Policy are as follows:
Where we need to perform the contract we are about to enter into or have entered into with you for the Services (e.g., under our Terms of Service).
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
Where we have your consent to process your information in a certain way.
Marco Polo may disclose your information in the following ways:
Affiliated entities. We may disclose information within Marco Polo to deliver the Services, operate our business, and enhance our Services and your customer experience.
Service providers. We use select third-party vendors (including those that utilize large language model and other artificial intelligence tools) to help us provide our Services and operate our business, and we may provide access to or disclose your information to these vendors. They provide a variety of services to us, including customer service, payment processing, data privacy management solution providers, marketing, in-app notifications, product design and development, data storage, security, fraud prevention, research, and legal services. These service providers are permitted to access and use your information for purposes of performing services for Marco Polo or to comply with applicable legal requirements.
Other Users. Consistent with our Terms of Service, we may disclose certain of your information to other users of Marco Polo Circles as part of the matching process.
Online advertising partners. As discussed in the "Online advertising" section above, we may disclose certain information about you to our online advertising partners to assist in our online advertising and measurement activities.
Publicly. If you choose to provide feedback or submit a review of the Services, such submissions may be published on the Services, in emails, television, and on social media platforms. Published reviews may identify your name and location, if provided. Do not submit any personal or sensitive information in connection with or in reviews that you do not want publicly published in these ways.
Protection of Marco Polo and others. We may disclose the information we collect about you if required to do so by law or in a good faith belief that such disclosure is reasonably necessary to: (a) comply with legal process (for example, a subpoena or court order); (b) enforce our terms of service or sale, this Privacy Policy, or other contracts with you, including investigation of potential violations; (c) respond to claims that any content violates the rights of third parties; or (d) protect the rights, property, or personal safety of Marco Polo or others.
Business transfers. As we continue to develop our business, we may engage in transactions with other companies regarding the purchase or sale of a business. We may disclose your information as part of, or in contemplation of, such transactions. If a portion or all of Marco Polo' assets are transferred to a third party in connection with such transactions, your information may be among the transferred assets.
Please note that Marco Polo operates its business from the United States, and processes the information collected under this Privacy Policy in the United States. The United States may have different privacy laws than those in your jurisdiction of residence. Marco Polo will process information in accordance with the protections in this Privacy Policy.
Our Services are intended for general audiences and are not directed at children. If we become aware that we have collected or processed data without legally valid parental consent from children under an age where such consent is required under applicable law, we will take reasonable steps to delete it as soon as possible.
The Services may contain links to third party websites and online services. This Privacy Policy does not apply to the practices of other websites and online services, and we are not responsible for the actions and privacy policies of the third parties that operate or interact with those other websites. Please see the applicable privacy policies for such other sites and services for information about their practices.
We are committed to protecting your information. We use a variety of technical, physical, and organizational security measures designed to protect against unauthorized access, alteration, disclosure, or destruction of information. However, no security measures are perfect or impenetrable. As such, we cannot guarantee the security of your information. Alert us immediately if you have any concerns about unauthorized use of your account.
We retain information for different periods of time depending on the purposes for which we collect and use it, as described in this Privacy Policy. We will delete or de-identify information when it is no longer needed to fulfill these purposes unless a longer retention period is required to comply with applicable laws. There may be technical or other operational reasons where we are unable to fully delete or de-identify your information. Where this is the case, we will take reasonable measures to prevent further processing of your information.
Consumer Data Rights. We provide you with the ability to exercise certain controls and choices regarding our collection, use, and disclosure of your information under applicable laws. Your legal rights to exercise such controls and choices vary based on the laws of your jurisdiction (i.e., residents of certain US states (currently including California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia) and residents of the EU, UK, and Canada) can exercise the following rights by contacting us at privacy@marcopolo.me.
If you have provided consent for us to use your information for a specific purpose, you may also request to withdraw that consent.
In addition:
California and Oregon residents can request information about the categories of information we collect, disclose or sell or share about you; California residents can request the sources of such information, the business or commercial purpose for collecting or selling or sharing your information; and the categories of third parties to whom we disclose information. Such information is also set forth in this Privacy Policy.
Oregon and Minnesota residents can request a list of the specific third parties, other than natural persons, to which we have disclosed information.
Residents of the EEA, UK, or Switzerland can lodge a complaint about our practices regarding your information with the supervisory authority of your country.
We may ask you to provide us with information necessary to reasonably verify your identity before responding to your request. We will consider all requests and provide our response within the time period required by applicable law. Please note, however, that certain information may be exempt from such requests. We will not discriminate against you or treat you differently for exercising your rights.
If you are a resident of Colorado, Connecticut, Delaware, Iowa, Indiana, Kentucky, Maryland, Minnesota, Montana, Oregon, Nebraska, New Hampshire, New Jersey, Rhode Island, Tennessee, Texas, or Virginia and we deny your information request, you have the right to appeal our denial. You can exercise this right by contacting us at the contact details provided at the bottom of this Privacy Policy. Your description must include your full name and the email address used for your account with us, along with a copy of the denial notice you received from us.
Targeted Advertising Opt Out Rights.
If you are a resident of one of the U.S. states listed above, you also have the right to opt out of our processing or "sharing" of your information for online targeted advertising purposes as well as from the "sale" of your information to third parties in exchange for valuable consideration. We do not "sell" your information in the traditional meaning of the term to third parties in exchange for money. However, our disclosure of hashed contact information to third parties such as social media platforms to assist in our advertising activities may be considered a "sale" or "sharing" under applicable law. To opt out of this activity, email us at privacy@marcopolo.me.
Our use of analytics or online advertising tools as described in the "Online advertising" section above may also result in the disclosure of your information to our third-party partners and that are subject to these opt out rights. You can opt out of these activities by clicking the "Your Privacy/Cookie Choices" link on our website footer. If you have a legally-recognized browser-based opt out mechanism installed on your device (e.g., Global Privacy Control), you will be automatically opted out of these activities.
Adjust your marketing and communication preferences:
Email marketing. In accordance with applicable legal requirements, we send you informational and transactional, and marketing emails, including regarding activities on the Service, like when you receive a Polo from one of your contacts. You may choose to unsubscribe from emails by clicking "Unsubscribe" at the bottom of the email. If you unsubscribe, we may still need to send you non-marketing emails about your account, our business dealings with you (e.g., emails regarding subscriptions you have with us), updates to our policies, or security notifications.
Text/SMS Marketing. Opt out of text (SMS/MMS) messages from us by following the instructions included in our messages, or by replying "STOP" to the last message received.
The information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations, including the United States, where the applicable data protection laws may differ from those in your country of residence. By using the Services, you acknowledge that these transfers will occur and that we take appropriate steps to transfer your information in accordance with this Privacy Policy and applicable law.
If you are a California resident, the California Consumer Privacy Act ("CCPA") requires us to provide you with the following additional information about: (1) the purpose for which we use each category of "personal information" (as defined in the CCPA) we collect; and (2) the categories of third parties to which we (a) disclose such personal information for a business purpose, (b) "share" personal information for "cross-context behavioral advertising," and/or (c) "sell" such personal information. Please see the following chart containing this information:
| Category of personal information | Purposes of use | Categories of 3rd parties to which Marco Polo discloses this personal information | Categories of 3rd parties to which Marco Polo "shares" and "sells" this Personal information for advertising/analytics |
|---|---|---|---|
| Contact information and Account information | Provide the Services; Communicate with you; Marketing and advertising; Personalize the Services; Improve the Services; Business Operations; With your consent | Affiliated entities; Service providers; Online advertising partners; Entities for legal purposes; Entities for business transactions | Online advertising partners (contact information only, in hashed form) |
| Financial information | Provide the Services; Communicate with you; Improve the Services; Business Operations; With your consent | Affiliated entities; Service providers; Entities for legal purposes; Entities for business transactions | We do not share/sell |
| Transaction history | Provide the Services; Marketing; Personalize the Services; Improve the Services; Business Operations; With your consent | Affiliated entities; Service providers; Entities for legal purposes; Entities for business transactions | We do not share/sell |
| Customer service information | Communicate with you; Improve the Services; Business Operations; With your consent | Affiliated entities; Service providers; Entities for legal purposes; Entities for business transactions | We do not share/sell |
| Your Content | Communicate with you; Personalize the Services; Improve the Services; Business Operations; With your consent | Affiliated entities; Service providers; Entities for legal purposes; Entities for business transactions | We do not share/sell |
For more information about each category, purpose of use, and the third parties to which we disclose or share information, please see the "Information we collect", "How we use your information," and "How we disclose your information" sections of our Privacy Policy.
Your Choices Regarding "Sale" and "Sharing"
As a California resident, you have the right to opt out of our processing or "sharing" of your information for online targeted advertising purposes as well as from the "sale" of your information to third parties in exchange for valuable consideration. We do not "sell" your information in the traditional meaning of the term to third parties in exchange for money. However, our disclosure of hashed contact information to third parties such as social media platforms to assist in our advertising activities may be considered a "sale" or "sharing" under California law. To opt out of this activity, email us at privacy@marcopolo.me.
Our use of analytics or online advertising tools as described in the "Online advertising" section above may also result in the disclosure of your information to our third-party partners and that are subject to these opt out rights. You can opt out of these activities by clicking the "Your Privacy/Cookie Choices" link on our website footer. If you have a legally-recognized browser-based opt out mechanism installed on your device (e.g., Global Privacy Control), you will be automatically opted out of these activities.
Other CCPA Rights
The CCPA also allows you to limit the use or disclosure of your "sensitive personal information" (as defined in the CCPA) if your sensitive personal information is used for certain purposes. Please note that we do not use or disclose sensitive personal information other than for business purposes for which you cannot opt out under the CCPA.
Please see the "Your Rights and Choices" section above for information about the additional rights you have with respect to your personal information under California law and how to exercise them. We will not discriminate against you for exercising these choices.
Retention of your personal information
Please see the "Retention of your information" section above.
Notice concerning Do Not Track
Do Not Track ("DNT") is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our websites for third-party purposes, and that is why we provide the variety of opt-out mechanisms listed above. Some web browsers offer users a "Do Not Track" privacy preference setting in the web browser. We do not currently recognize or respond to browser-initiated Do Not Track signals.
California "Shine the Light" Notice
The California "Shine the Light" law gives residents of California the right under certain circumstances to opt out of the disclosure of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes, or in the alternative, that we provide a cost-free means for consumers to opt out of any such disclosure. We do not currently disclose your personal information to third parties for their own direct marketing purposes. To opt out of activities that are considered "sales" or "sharing" under California law, please see the "Your Choices Regarding 'Sale' and 'Sharing'" section above.
From time to time we may change or update this Privacy Policy to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. You should review the Privacy Policy periodically, and you can know if the Privacy Policy has changed since the last time you reviewed it by checking the "Last Updated" date at the beginning of the document. By continuing to use the Services, you are confirming that you have read and understood the latest version of this Privacy Policy. If we make material changes to the Policy, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective, in accordance with applicable legal requirements.
We welcome your comments or questions about this Policy. You may contact us at privacy@marcopolo.me.
2025 © Joya Communications Inc.
| Demographic Information | Communicate with you; Marketing and advertising; Personalize the Services; Improve the Services; Business Operations; With your consent | Affiliated entities; Service providers; Online advertising partners; Entities for legal purposes; Entities for business transactions | We do not share/sell |
| Surveys and sweepstakes information | Communicate with you; Personalize the Services; Improve the Services; Business Operations; With your consent | Affiliated entities; Service providers; Entities for legal purposes; Entities for business transactions | We do not share/sell |
| Information collected through automated technologies | Provide the Services; Marketing and advertising; Personalize the Services; Improve the Services; Business Operations; Recognize a user across multiple touchpoints; With your consent | Affiliated entities; Service providers; Online advertising partners; Entities for legal purposes; Entities for business transactions | Online advertising partners |