Privacy policy.
What we do with your information.

Circle Group provides Paraguay-focused services to clients and prospects in our current service markets: the European Union, the United Kingdom, the United States, Canada, Australia, New Zealand, Argentina, Bolivia, Brazil, Chile, Colombia, Ecuador, Guyana, Peru, Suriname, Uruguay, Japan, South Korea, Singapore and the United Arab Emirates.

Privacy laws do not all apply in the same way. A regional law may depend on where you are, where processing takes place, the nature of our activities, and any thresholds or territorial rules in that law. Where a law applies to our processing of your information, we will respect the rights and obligations it gives you. If local law provides greater protection than this policy, the local law controls.

We collect information you choose to give us, which may include your name, email address, phone or WhatsApp number, country, language, residency status, goals, service interests, timeline, investment or budget range, business or income structure, questionnaire answers, booking details, communications and information needed to deliver a service you request.

If you become a client, we may also collect records needed to coordinate your matter, such as company, accounting, immigration, banking, property, investment or compliance information. We only ask for sensitive or higher-risk information when it is reasonably necessary for the service or where law requires it.

Where permitted, we record first-party website and CRM data so we can understand how an enquiry reached Circle Group and what happened afterwards. This can include an anonymous visitor or session identifier, landing page, referrer, UTM parameters, campaign, ad and ad-set identifiers, language, broad country, browser and device category, and the dates of important lifecycle events.

We classify identifiable traffic into channels such as organic search, organic social, referral, AI referral, paid search, paid social and direct. AI referrals may be normalized to sources such as ChatGPT, Perplexity, Claude, Gemini or Copilot when the referring product or an explicit campaign source can be identified.

Advertising click identifiers such as gclid, gbraid, wbraid or fbclid are stored only where marketing tracking is permitted. We do not store your IP address in the CRM attribution record.

We use personal information to respond to enquiries, assess what service may be relevant, prepare for consultations, schedule meetings, operate our CRM, route work internally, provide and improve services, maintain records, prevent misuse, understand acquisition and conversion performance, and comply with legal or regulatory obligations.

Depending on the context and the law that applies, our legal basis may be your consent, steps taken at your request before entering into a contract, performance of a contract, compliance with a legal obligation, or our legitimate interests in operating and improving Circle Group where those interests are not overridden by your rights.

We do not sell personal information.

This website uses necessary browser storage for core functions and privacy settings. Optional analytics and advertising technologies are controlled according to the privacy regime that applies where you access the site.

Where prior opt-in is required, relevant analytics or marketing technologies remain off until you choose them. Where an opt-out model is permitted, they may operate by default and you can change your choice at any time through Cookie settings.

We may use Google Analytics for audience and site-performance measurement, and Google Ads and Meta technologies for advertising measurement. We honor supported browser privacy signals such as Global Privacy Control for marketing tracking.

We may share information with people and organisations that help us operate or deliver the service you asked for, such as accountants, immigration specialists, lawyers, banks, brokers, property professionals, advisers, technology providers, cloud hosting, email, analytics, advertising, calendar and video-meeting providers.

We only share what is reasonably necessary for the relevant purpose. We may also disclose information where required by law, court order or a competent authority, or where reasonably necessary to protect rights, security or prevent fraud.

Circle Group operates internationally and some service providers or specialists may process information outside the country where you live. This can include processing in Paraguay and in countries where our technology or professional providers operate.

Where applicable law requires safeguards for international transfers, we use appropriate contractual, organisational or other lawful measures and provide additional information where required.

We keep personal information only for as long as reasonably necessary for the purpose for which it was collected, to maintain an active relationship, follow up an enquiry, provide services, resolve disputes and meet legal, accounting, tax, professional or record-keeping obligations.

Different records may therefore be kept for different periods. When we no longer need information and no legal reason requires us to retain it, we delete, anonymise or securely archive it as appropriate.

We may use rules, lead scores or questionnaire answers to route enquiries, prioritise follow-up or identify which Circle service or adviser is most relevant. These tools support our team; they do not currently make solely automated decisions that produce legal or similarly significant effects for you.

Where applicable law gives you rights relating to automated decision-making or profiling, you may contact us to ask for information or human review.

Depending on the law that applies, you may have rights to know what information we hold, obtain access or a copy, correct inaccurate information, request deletion, object to or restrict processing, withdraw consent, request portability, opt out of certain advertising uses, and complain to a privacy regulator.

To exercise a right, contact us using the address below. We may need to verify your identity before acting on a request. We will not discriminate against you for exercising a privacy right.

Where the EU GDPR or UK GDPR applies, you may have rights of access, rectification, erasure, restriction, objection and data portability, as well as the right to withdraw consent and to complain to the competent supervisory authority. You may also have rights relating to certain automated decisions.

For visitors subject to these regimes, we keep relevant non-essential analytics and marketing storage off until the required consent is obtained. Where we rely on legitimate interests, you may object in the circumstances provided by law.

Where Paraguay's Law 7593/2025 applies, we provide information about the categories of data processed, our purposes and legal basis, recipients and international transfers, retention criteria and the mechanisms available to exercise your rights.

Applicable rights include access, rectification, opposition, deletion and portability, together with the right to approach the competent supervisory authority. Requests are handled through our privacy contact and subject to the identity-verification and other requirements permitted by law.

For Brazil, where the LGPD applies, rights may include confirmation of processing, access, correction, deletion or anonymisation in qualifying circumstances, portability where applicable, information about sharing, withdrawal of consent and recourse to the ANPD. Our marketing tracking remains off until the required choice is made under our Brazil configuration.

For Argentina, applicable rights include access, rectification, updating and deletion or suppression, together with recourse to the AAIP where the law provides it.

For clients and prospects in Bolivia, Chile, Colombia, Ecuador, Guyana, Peru, Suriname and Uruguay, we will also honour additional access, correction, deletion, objection, consent or complaint rights provided by applicable local privacy law. Local law controls where it provides stronger rights than this policy.

In Canada, where PIPEDA or an applicable provincial privacy law applies, you may have rights to access personal information, challenge its accuracy and request correction, withdraw consent in appropriate circumstances and complain to the relevant privacy authority. Québec visitors receive the prior-consent treatment configured for non-essential tracking.

In the United States, privacy rights vary by state and by whether a particular law applies to Circle Group. Applicable rights may include access or knowledge, correction, deletion, portability and the right to opt out of sale, sharing or targeted advertising. Circle Group does not sell personal information, and we honor supported Global Privacy Control signals for marketing tracking.

Where Australia's Privacy Act and Australian Privacy Principles apply, you may request access to and correction of personal information and may raise a privacy complaint. We also provide information about the purposes for which information is collected, used and disclosed and about relevant overseas handling where required.

Under New Zealand's Privacy Act 2020 where applicable, you may request access to and correction of personal information and complain to the Office of the Privacy Commissioner.

In Japan, where the APPI applies, you may have rights concerning disclosure, correction, addition or deletion of retained personal data and, in qualifying circumstances, suspension of use or deletion. Complaints may be directed to us and, where appropriate, to Japan's Personal Information Protection Commission.

In South Korea, where the PIPA applies, rights can include access, correction or erasure, suspension of processing and other rights provided by law. Our South Korea tracking configuration requires prior choice for relevant non-essential tracking.

In Singapore, where the PDPA applies, you may request access to and correction of personal data, withdraw consent with reasonable notice and raise concerns about our handling of your information. Cross-border transfers are handled in accordance with applicable transfer requirements.

The United Arab Emirates is the only Middle Eastern market currently included in Circle Group's service-market scope. Where the UAE Personal Data Protection Law applies, we process personal data in accordance with its consent, security, confidentiality and data-subject-rights requirements, subject to the law's exceptions and territorial rules.

If you are in the UAE and wish to exercise an applicable privacy right or raise a concern, contact us using the privacy contact below.

We use technical and organisational measures intended to protect personal information against unauthorised access, loss, misuse, alteration or disclosure. Access to CRM and client information is limited according to role and operational need.

No internet or storage system can be guaranteed completely secure. If a breach occurs, we will assess and notify affected people or authorities where applicable law requires it.

Circle Group's services are intended for adults and business users. We do not knowingly design our enquiry or marketing systems for children. If we learn that we collected a child's personal information in circumstances that require parental consent or deletion, we will take the steps required by applicable law.

We may update this policy when our services, technology or legal obligations change. The date at the top of this page shows the latest revision. If a change materially affects your rights, we will provide additional notice where required.