Privacy Policy
Last updated: 11 October 2026
This policy explains what personal data Circoplex collects through circoplex.com, why, who sees it and what rights you have. If anything is unclear, email info@circoplex.com.
Who we are
Circoplex is run by Ben Lowrey, a sole trader. Ben Lowrey is the “controller” of your personal data under the UK GDPR and the Data Protection Act 2018, which means he decides how and why it is used.
Ben Lowrey, sole trader, trading as CircoplexEmail: info@circoplex.com
What we collect, why and for how long
| What | Why | Our legal basis | How long |
|---|---|---|---|
| Contact form: your name, email address and message. | To read and reply to your message. | Legitimate interests (answering people who write to us). | Up to 2 years after our last message to you, then deleted. |
| Free 7-Day Handstand Starter sign-up: your email address, your first name if you give it, your confirmation that you are 18 or over, the wording you agreed to and when, the page you signed up from (and any partner or campaign code in the link), whether you confirmed and unsubscribed, and one-way (keyed) scrambles of your IP address and browser details. | To send you the confirmation email and the Starter emails, to prove that you agreed, to honour your unsubscribe, and to stop abuse. | Your consent (confirmed by clicking the link in the first email). Legitimate interests for the records that prove consent and stop abuse. | Sign-ups you never confirm are deleted after 30 days. If you confirm, we keep your details until you unsubscribe or ask us to delete them. The consent record (a one-way scramble of your email address, the wording and the time) is kept so we can prove consent and never email you after you unsubscribe. |
| Visits to our niche pages (the “Find your path” pages): which page and version you saw, any partner or campaign code in the link, and one-way (keyed) scrambles of your IP address and browser details. No cookie is used for this unless you accept Analytics cookies. | To test which wording on a page helps people most, and count how many visits lead to sign-ups. | Legitimate interests (improving the site). | 14 months, then deleted. |
| Your cookie choice and when you made it, kept in a cookie called circoplex_consent. | To remember your choice and respect it. | Legitimate interests (we must be able to honour your choice). | 6 months, or until you change it. |
| Analytics, only if you accept Analytics cookies: pages viewed, approximate location, device and browser type, and a random ID stored in a cookie. Collected by Google Analytics. | To understand how the site is used and improve it. | Your consent. | The cookies last up to 2 years. Google Analytics keeps the data for no longer than 14 months. |
| Advertising measurement, only if you accept Advertising cookies: pages viewed, actions on the page such as clicking a button or starting checkout, and a random ID stored in a cookie. Collected by the Meta Pixel and Google Ads. | To measure how well our adverts work and to show our adverts to people who have visited. | Your consent. | The cookies last up to 3 months. Meta and Google keep the data under their own policies. |
| Partner referrals: if you arrive through a link from one of our partners (a teacher or creator who recommends Circoplex), the partner’s code is kept with your checkout. If you accept Advertising cookies, the code and the date are also kept in a cookie called circoplex_partner, so a purchase you make later still counts for that partner. We count visits through each partner’s link without recording who made them. | To pay the partner commission on a purchase they referred. Partners see only the date, the amount after tax and their commission, never your name or email address. | Legitimate interests (paying the people who recommend us) for the checkout record; your consent for the cookie. | The cookie lasts 30 days. Commission records are kept for 6 years for tax. |
| Partners in our referral programme: name, public handle, email address, how you want to be paid and where your payment details are kept (never your bank or card numbers), and the commission records for sales you referred. | To run the programme, show you your statement and pay you. | Contract (the partner terms) and legal obligation (tax records). | While you are a partner, then 6 years for tax. |
| Studios, schools, teachers and creators we invite to the partner programme: your organisation or professional name, website and public profile links, the business email address you publish and the page it is on, public audience figures, and our emails with you. | To invite you to a commercial partnership. We email once, follow up once, and stop if you say so. | Legitimate interests (inviting a business to a commercial partnership). | Reviewed after 12 months. If you ask us to stop, we keep only a scrambled (hashed) copy of your address so we never contact you again. |
| Videos, only when you press play: your IP address, browser and device details and the video you are watching are sent to Mux, our video host, which streams it to you. Mux sets no cookies and collects no viewing analytics on this site. Each video’s cover picture is a still from that video, which our own site fetches from Mux and serves to you, so Mux receives nothing from you before you press play. In Chrome, pressing play also loads Google’s Cast library (from gstatic.com) so you can send the video to a TV; Google then sees your IP address. | To play the video you asked for. | Legitimate interests (delivering the video you asked for). | Short-term, under Mux’s log retention. |
| Technical logs: IP address, browser type, pages requested, date and time. Kept by our hosting provider, Vercel. | To deliver the site, keep it secure and fix faults. | Legitimate interests. | Short-term, under Vercel’s log retention. |
We do not ask for “special category” data such as health information. If you choose to tell us about an injury or health condition in a message, we use it only to reply to you.
If you buy lifetime access
When you buy the Ultimate Handstand Library we use the following personal data, for the reasons shown.
| What | Why | Our legal basis | How long |
|---|---|---|---|
| Your name, email address, country and the amount you paid. Your card details go straight to Stripe/Link; we never see them. | To take payment, give you access, send your access email and handle refunds. | Contract (we need it to supply what you bought). | For as long as you have access. |
| Records of the purchase, refunds and any dispute. | To keep accounts and meet tax rules. | Legal obligation. | Six years. |
| The record that you asked for your access to start straight away: the version of the wording next to the box you ticked, the time, and a one-way scramble of your email address, internet address and browser. | To prove you gave the consent the Consumer Contracts Regulations 2013 require for instant access. | Legal obligation. | Six years. |
| Which lessons you have started and finished. | To show your progress and send a reminder if you have not started. | Contract. | For as long as you have access. |
| Signs that a login is being shared (for example many different locations at once). | To protect the library from copying and misuse. | Legitimate interests. | Short-term logs. |
To do this we use: Stripe/Link, which processes payments. Payments are processed by Stripe/Link (Onelink, LLC) as merchant of record. Onelink, LLC sends your payment receipt, and the charge appears on your statement as LINK.COM* CIRCOPLEX. Circoplex sends a separate access confirmation. Clerk, which looks after your sign-in. Mux, which streams the videos. Resend, which sends your access email. Each handles your data on our behalf, under contracts that limit what they can do with it.
Who we share it with
- Resend, which delivers contact form messages to our inbox and sends you the confirmation and Starter emails.
- Supabase, which hosts the database that holds Starter sign-ups.
- Google, which hosts our email inbox (Google Workspace) and, if you accept Analytics or Advertising cookies, provides Google Tag Manager (which loads only the tools you allowed), for Analytics, Google Analytics and, for Advertising, Google Ads.
- Mux, which hosts and streams our videos when you press play.
- Meta Platforms, if you accept Advertising cookies.
- Vercel, which hosts this website.
- Cloudflare, only if the optional robot check on the contact form is switched on: your browser then contacts Cloudflare when you start filling in the form.
Some of these act on our instructions (as our “processors”). Google Analytics, Google Ads and Meta also use data for their own purposes under their own privacy policies. We do not sell your personal data. We may share it if the law requires, or to protect our legal rights.
Sending data outside the UK
Several of these companies are based in the United States. When your data leaves the UK we make sure it stays protected, for example by relying on the UK–US data bridge for certified companies, or on the UK’s approved standard contract terms (the International Data Transfer Agreement or the UK Addendum to the EU standard contractual clauses).
Cookies
Optional cookies are off until you switch them on. The Cookie Policy lists every cookie, and “Cookie settings” in the footer lets you change your mind at any time.
Your rights
You have the right to:
- be told how your personal data is used (this policy);
- see the personal data we hold about you and get a copy;
- have inaccurate data corrected;
- have your data erased, in many cases;
- ask us to restrict how we use your data;
- receive the data you gave us in a portable format, where we use it because of your consent or a contract;
- object to us using your data for our legitimate interests, or for direct marketing;
- withdraw your consent at any time, for example with Cookie settings. Withdrawing does not affect anything done before you withdrew;
- not be subject to decisions made only by automated means. We do not make any.
How to use your rights
Email info@circoplex.com with “Privacy request” in the subject line. We will reply within one month. We may ask you to prove who you are, so that we do not give your data to the wrong person. There is no charge unless a request is clearly unfounded or excessive.
Complaints
If you are unhappy with how we have handled your personal data, please tell us first: email info@circoplex.com with “Privacy complaint” in the subject line. We will acknowledge your complaint within 30 days of receiving it and respond without undue delay.
You can also complain to the Information Commissioner’s Office (ICO) at ico.org.uk/make-a-complaint or on 0303 123 1113. The ICO usually asks that you contact us first.
Children
Circoplex is for adults. We do not knowingly collect personal data from anyone under 18.
Keeping your data safe
Data between your browser and this site travels over encrypted (HTTPS) connections.
Changes to this policy
If we change how we use personal data we will update this page and the date at the top.