Privacy Policy — ClipCircle

Last updated: 26 October 2026

This Privacy Policy describes how Hantropos S.r.l. ("ClipCircle", "we", "us", "our") collects, uses, stores and shares the personal data of users who access the website clipcircle.net and its related video-sharing services (collectively, the "Services"). The company has its registered office at Via Inganni 34 – 20147 Milan (MI), Italy.

ClipCircle is a video-sharing service offering features similar to platforms such as Rumble.com. We process personal data in accordance with Regulation (EU) 2016/679 – GDPR, Italian Legislative Decree No. 196/2003 (Privacy Code) as amended by Legislative Decree No. 101/2018, and applicable European and Italian laws on data protection and information society services.

By using the Services, you acknowledge that you have read and understood this Privacy Policy. We encourage you to review it periodically: material changes will be notified by a prominent notice on the website and by updating the date at the top of this document.

1. Data Controller

The Data Controller is:

Hantropos S.r.l.
Via Inganni 34 – 20147 Milan (MI), Italy
Email: legal@clipcircle.net

For any request relating to this Privacy Policy or the exercise of data subject rights, you may write to legal@clipcircle.net or use the contact details provided on the page https://clipcircle.net/contact-us.

2. Categories of Personal Data Collected

We collect the following categories of personal data:

• Registration data and identifiers: name, alias, email address, phone number (if provided), username, password, profile picture, biographical information and similar data.

• Profile data and content: uploaded videos, titles, descriptions, thumbnails, comments, messages and any other content published through the Services.

• Usage and browsing data: IP address, browser type, operating system, device model, unique identifiers, pages visited, searches performed, access times and dates, and other statistics automatically collected ("Automatically Collected Information").

• Payment and tax data: where applicable, data necessary to manage paid accounts and to comply with tax obligations (e.g. tax codes or VAT numbers). Specific details concerning paid accounts will be added at a later stage with dedicated provisions.

• Sensitive data (special categories): we do not require special categories of data for ordinary use of the Services. Where you voluntarily provide such data (e.g. political opinions expressed in published content), processing will be based on your explicit consent.

• Inferences and preferences: information inferred from your activities to personalise content and advertising.

3. Purposes and Legal Bases for Processing

We process personal data for the following purposes and on the following legal bases under Article 6 GDPR:

4. Method of Processing

Processing is carried out using electronic and telematic tools, with logic strictly related to the purposes indicated, and by adopting appropriate technical and organisational measures to ensure the security, integrity and confidentiality of data, in accordance with Articles 5 and 32 GDPR.

5. Disclosure of Data

Personal data may be disclosed to:

• Other users: your username, channel name and published content are visible to other users. Sharing additional data is voluntary.

• Service providers: third parties providing services on our behalf (hosting, web analytics, maintenance, fraud prevention, communications delivery), appointed as data processors under Article 28 GDPR and bound not to use the data for their own purposes.

• Advertising partners: for the delivery of personalised advertising, subject to your consent.

• Public authorities: where required by law, judicial or administrative order.

• Parties in corporate transactions: in the event of a merger, acquisition, sale of a business unit or similar transactions, data may be transferred to successors in accordance with applicable law.

Data are not disseminated to third parties for purposes other than those indicated without the data subject's consent.

6. International Data Transfers

Personal data are primarily processed within the European Economic Area (EEA). Should it be necessary to transfer them to third countries, the transfer will be based on an adequacy decision of the European Commission or, failing that, on appropriate safeguards under Articles 46 and 47 GDPR (e.g. Standard Contractual Clauses). You may request further information by writing to legal@clipcircle.net.

7. Data Retention

Personal data are retained for the time strictly necessary to achieve the purposes for which they were collected and, in any case:

• account data: until account deletion or for the period necessary to provide the Services;

• tax and accounting data: for the period required by law (generally 10 years);

• browsing and log data: for a limited period proportionate to security and analytics purposes;

• data processed for marketing purposes: until consent is withdrawn.

8. Data Subject Rights

Under Articles 15-22 GDPR, you have the right to:

• Access: obtain confirmation of processing and a copy of your personal data;

• Rectification: correct inaccurate data or complete incomplete data;

• Erasure ("right to be forgotten"): obtain deletion of data, in the cases provided by law;

• Restriction: request restriction of processing;

• Portability: receive data in a structured, commonly used and machine-readable format;

• Objection: object to processing based on legitimate interest and to profiling;

• Withdrawal of consent: withdraw consent at any time, without affecting the lawfulness of processing carried out before withdrawal;

• Complaint to a Supervisory Authority: lodge a complaint with the Italian Data Protection Authority (www.garanteprivacy.it) or the competent supervisory authority of your Member State of residence.

Requests may be sent to legal@clipcircle.net or via the page https://clipcircle.net/contact-us. We will respond within the time limits set by Article 12 GDPR (generally within one month). We may request additional information to verify the requester's identity.

9. Cookies and Tracking Technologies

The Services use cookies and other tracking technologies (e.g. pixels, web beacons, local storage) to ensure the proper functioning of the website, analyse usage, personalise content and advertising.

For detailed information on the types of cookies used, their purposes and how to manage your preferences, please refer to the Cookie Policy, available on a separate page of the website. For EU/EEA and UK users, non-essential cookies are installed only with valid consent, manageable through the dedicated banner.

10. Data Security

We adopt appropriate technical and organisational measures to protect personal data against loss, misuse, unauthorised access, disclosure, alteration or destruction, in accordance with Article 32 GDPR. However, no system is completely secure: we cannot guarantee the absolute security of information transmitted over the Internet.

11. Children

The Services are not intended for persons under 18 years of age. We do not knowingly collect personal data from anyone under 18. If we become aware of unauthorised collection, we will delete the data. Parents or guardians may contact us at legal@clipcircle.net.

12. Links to Third-Party Sites

The Services may contain links to third-party websites or services that apply their own privacy policies. We are not responsible for the practices of such third parties and encourage you to review their respective notices.

13. Changes to this Privacy Policy

We reserve the right to update this Privacy Policy at any time. Changes will be published on this page together with the date of the last update. In the event of material changes, we may provide a more prominent notice. Continued use of the Services after the update constitutes acceptance of the new version.

14. Contact

Hantropos S.r.l.
Via Inganni 34 – 20147 Milan (MI), Italy
Email: legal@clipcircle.net
Contact page: https://clipcircle.net/contact-us