Circulate

Legal

Privacy Policy

Last updated: 27 June 2026

Circulate Limited (“Circulate”, “we”, “us”, or “our”) operates a flyer delivery platform that connects businesses (“Clients”) with independent contractors (“Distributors”) to complete local delivery jobs. We are committed to protecting your privacy.

This Privacy Policy explains how we collect, use, store, share, and protect your personal information across our website, app, and related services (“Services”). Other terms and conditions may apply to your use of our Services.

We may update this Privacy Policy from time to time. If we make significant changes, we will notify you by email, website or in-app notice, or by other communications. We encourage you to regularly review this Privacy Policy for the latest information on our privacy practices.

1. What personal information does Circulate collect and why?

The personal information we collect from you depends on how you use Circulate or interact with us. We generally collect your personal information from you directly to provide our services. In some cases, we may collect some information indirectly. For example, if another user has provided feedback about you regarding a delivery job.

Category of information What we may collect Why we collect it
Account information

This may include:

  • name;
  • email address;
  • phone number;
  • user role, such as client or distributor;
  • date of birth, if you are a distributor; and
  • profile photo, if provided.

If you are a Client, we may also collect your business name and details, including NZBN.

We use this information to:

  • create and manage your account;
  • verify age, if you are a distributor;
  • administer our services;
  • personalise your account or improve the user experience;
  • support you if something goes wrong; and
  • help prevent fraud or misuse.
Payments, invoices, and payouts

This may include:

  • GST number;
  • payment references, refund records, and tax invoices;
  • saved-card consent records if you choose to save a card;
  • Stripe account or payment references; and
  • payout records.

We use this information to:

  • process payments and refunds;
  • issue invoices and distributor payouts;
  • manage our legal and tax obligations;
  • maintain tax accounting records; and
  • provide payment support.

We do not store full card numbers or bank-account details. Full bank account details are held by our payment provider, Stripe, and not directly by Circulate.
Location information

If you are a Distributor, we use GPS tracking to record your location in real time when you are actively delivering a job.

We use this information to:

  • verify route coverage;
  • produce proof-of-delivery and coverage reports for clients;
  • support payment for completed work;
  • resolve delivery disputes;
  • investigate fraud, misuse, or anomalies;
  • support distributor safety; and
  • improve delivery operations and platform quality.

Distributors can also enable location services while browsing available jobs to find jobs near them. We do not retain a record of your location for this purpose.
Campaign and delivery details

This may include:

  • delivery zones drawn by clients on the map;
  • saved delivery areas;
  • recurring-campaign schedules;
  • estimated address counts;
  • pricing and quote information;
  • campaign material details;
  • pickup, handover, and delivery instructions;
  • job acceptance and completion data;
  • delivery notes and completion surveys;
  • proof-of-delivery and coverage reports; and
  • photos attached to support requests.

We use this information to:

  • price, manage, complete, and report on flyer delivery campaigns;
  • resolve delivery disputes;
  • investigate fraud, misuse, or anomalies;
  • support distributor safety; and
  • improve delivery operations and platform quality.
Distributor reliability, safety, and quality information

This may include:

  • job acceptance history;
  • job completion history;
  • route-coverage results;
  • delivery-confidence results;
  • fraud or anomaly flags;
  • client ratings and notes;
  • delivery exceptions;
  • escalation or dispute history; and
  • account warnings, restrictions, or suspension status.

We use this information to:

  • operate our services safely and fairly; and
  • manage job access, payouts, disputes, safety, fraud prevention, and platform integrity.
Support and communications

This may include:

  • messages, enquiries, and support requests you send to us;
  • emails, SMS messages, and other service communications we send to you; and
  • records of complaints, disputes, or platform-support interactions.

We use this information to:

  • provide our services;
  • communicate with you;
  • provide support and send service updates; and
  • keep records of important communications.
Technical and usage information

This may include:

  • IP address;
  • device type;
  • browser type;
  • operating system;
  • app version;
  • server logs;
  • authentication/session information;
  • diagnostic and error information; and
  • page views and basic performance analytics.

We use this information to:

  • keep the website and app working;
  • secure the platform;
  • fix bugs;
  • understand basic usage; and
  • improve our services.

We may use cookies, local storage, or similar technologies where needed for login sessions, security, preferences, analytics, and service operation.

2. Does Circulate collect any personal information indirectly?

We will generally collect your personal information directly from you. However, sometimes we may collect personal information from someone else or from another source.

For example, we may collect personal information indirectly from:

  • clients providing pickup addresses, pickup notes, site contact details, or campaign logistics;
  • clients rating or leaving notes about a distributor after a delivery and vice versa; and
  • public New Zealand address data used to estimate address counts, model delivery zones, and provide delivery-proof context.

3. Why does Circulate collect location information?

Circulate uses Distributor device-enabled GPS tracking to collect location data during active delivery jobs. Distributors must enable location permissions to accept or complete delivery jobs. Clients who have active bookings can review real-time delivery reports of a Distributor’s completion of the delivery route, together with delivery totals and related proof-of-delivery outputs.

Location tracking:

  • must be enabled for a Distributor to start an accepted job;
  • starts only when a Distributor taps Start tracking on an accepted job;
  • is collected while the delivery is actively in progress;
  • may continue in the background while the phone is locked, so the delivery route can be recorded for the full run; and
  • stops automatically when the Distributor pauses an active job or ends a completed delivery.

We do not use GPS tracking to monitor distributors outside an active delivery job.

4. Who do we share your personal information with?

We share personal information, where reasonably needed, to operate Circulate and provide our services, meet our legal obligations, protect our rights, with your authorisation, or in connection with a sale, merger, restructure, subject to appropriate protections.

We may share information with:

  • clients, for their own campaign reporting and proof of delivery;
  • distributors, where they need job details to complete an accepted delivery;
  • Stripe, for payments, saved-card functionality, distributor onboarding, and payouts;
  • service providers that help us run hosting, maps, email, SMS, analytics, app services, and support;
  • Circulate staff, contractors, or operators who need access for support, operations, safety, fraud prevention, payments, or compliance;
  • professional advisers, regulators, tax authorities, courts, or other authorities where required or allowed by law; and
  • purchasers or successors of our business or assets if we, or any of our businesses, are sold or disposed of, whether by merger, sale of assets or otherwise, or in the event of insolvency, bankruptcy or receivership. Your personal information may be one of the assets sold or merged in connection with the transaction.

5. How does Circulate store and secure personal information?

We only keep personal information for as long as reasonably needed for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law. Where information is no longer required, we will take reasonable steps to delete, de-identify, anonymise, or securely archive it.

We take reasonable technical and organisational steps to protect your personal information from loss, misuse, unauthorised access, unauthorised disclosure, modification, and interference.

No internet-based service is completely secure. You are responsible for keeping your login details secure and promptly letting us know if you believe your account has been accessed without permission.

6. How do I opt out of marketing communications?

If you register your interest to sign up for a Circulate pilot or opt in to receive marketing communications, we may send you pilot-related and service updates and occasional product news. You can unsubscribe from marketing communication at any time by following the relevant unsubscribe instruction in that communication.

Even if you opt out of marketing, we will continue to send you transactional service messages or notices that we are required by law to send. Transactional service messages include booking confirmations, delivery updates, monthly and annual reports, and security or verification messages.

7. Deleting your account

You can delete your account at any time in the app. For clients, this is available through Profile or Settings. For distributors, this is available through Profile. Please contact us using the details below if you need help with this.

Deleting your account does not fully erase records that we are required or permitted to keep by law, such as legal and accounting records.

8. How to access and correct your personal information

Your personal information will be held by Circulate Ltd. We take reasonable steps to keep the personal information we use accurate, up to date, complete, relevant, and not misleading. You can update your account details at any time using your account settings.

You can also request to access or correct the personal information we hold about you by contacting our Privacy Officer at privacy@circulate.nz. We may need to verify your identity before considering your request.

If you are not satisfied with our response, you can contact the New Zealand Office of the Privacy Commissioner.

9. Contact us

Please direct: