Who we are
Opal Circle is a private membership community for women navigating divorce or bereavement, operating in the United Kingdom and the United States.
Opal Circle Ltd is registered in England and Wales. Our registered office is Suite F, Bishops Walk House, 19-23 High Street, Pinner HA5 5PJ, and our company number is 17260986. We are registered with the Information Commissioner's Office, the UK's data protection regulator, under reference ZC256757. We are the data controller for the information described in this policy, which means we decide what is collected and why.
A note on how this is written. We have tried to write this in plain language, because a policy nobody reads protects nobody. Where we have had to use a technical term we have explained it.
What this policy covers
Everything we hold about you, whether you are:
- Someone who has downloaded a guide or joined our early-access list
- Someone who has used the Journey Tool
- Someone who has applied to join, or is on our waitlist
- A member
- A professional in our provider network, or applying to join it
- Someone a professional has named as a referee
- Someone who has written to us
It covers our website, our membership platform, our emails and our events.
What we collect, and when
When you download a guide
Your email address, and nothing else. We email you a link to the guide, which works for seven days.
If you joined our early-access list before the platform opened, we hold what you gave us then: your first name, your email address, your country, and anything you wrote in the open field.
When you apply to join
- Your full name and email address
- A name to appear under in the community, if you would like one that is different from your own
- Whether you are based in the United States, the United Kingdom or somewhere else. If it is somewhere else, we add you to our waitlist.
- Whether you are navigating a divorce, a bereavement, or both
- A broad indication of your financial situation, given as a range. "I am not sure yet" is one of the options.
- What you most need right now
- Whether anyone else uses the devices you sign in from, so we know how quickly to sign you out
- If you choose to tell us: how you heard about us, the name of whoever referred you, and anything else you would like us to know
When we speak to you
Every application is read by a person, and every applicant has a conversation with us before joining. You book that conversation through Calendly, a scheduling service, which holds your name, your email address and the time you chose. We keep a short note of the conversation with your application.
When you use the Journey Tool
The Journey Tool asks about your circumstances so it can show you where you are and what typically comes next. The questions cover whether you are facing divorce or bereavement, whether you are in the UK or the US, how far along you are, and which areas of life apply to you, such as children, work, dating and your wellbeing.
Some of those answers are sensitive, so we ask for your consent before they are saved.
Your answers and your result are saved without your name or email address. They are linked to you only if you ask us to email your result, or if you are signed in as a member. To open a saved result later, we send a six-digit code to your email address, so only someone who can read your inbox can open it.
While you are part way through, your progress is kept in your own browser so you can pause and come back.
You never have to use it. It is something we offer, not something we require, and you can be a member without ever taking it.
When you are a member
- Your email address, and your password in a form we cannot read. If you sign in with Google instead, Google tells us your name, email address and profile picture.
- Your name and the name you chose to appear under
- What you post, comment or send inside the community
- The spaces you belong to, the workshops you book and your notification settings
- Which stage of your journey you have chosen to display, if you display it at all
When you ask to be introduced to a professional
The request form asks what you would like help with, anything you want our team to know but not pass on, anything the professional should not be told yet, and which email address we should use. You also choose between letting us share your first name and a brief summary, or staying anonymous until you have spoken to the professional. If you would rather talk it through with us first, you can ask for that instead.
Your request reaches our team by email, and a person makes the introduction. We keep your request and a record of who we introduced you to.
If you are a professional in our provider network
When you apply, we collect your name, email address, firm, where you are based, the jurisdictions you work in, your field and a description of your work.
As part of our assessment, we ask for your qualifications, your regulator, your licence or registration number, your professional memberships, and the names, organisations and email addresses of two referees. You confirm the details are accurate and consent to us checking your credentials and regulatory standing. Your interview with us is booked through Calendly.
For your listing, we collect a contact name, job title, website, contact email, phone number and an optional backup contact, together with your categories and specialisms, where and how you work, your biography and experience, your languages, your fee structure, any minimum asset level, a photograph and, if you wish, a logo. With your consent we publish your profile in our directory, which only approved members can see. Your contact details are not shown there. Members reach you through us.
If a professional has named you as a referee, we hold your name, organisation and email address, which they gave us. We use them only to ask you for a reference, and we keep them only as long as we keep the application they belong to.
When you contact us
The contact form asks for your name, your email address, a topic and your message. It reaches our team inbox as an email and is not stored on the platform. The same goes for anything else you email us, and we keep our reply.
Technical information
We do not run analytics on our website.
The companies that host our website and servers keep standard logs: your IP address, the pages requested, the time and your browser type. A log can also contain an email address, for example when you sign in or when an email to you fails to send. Logs are kept for 30 days.
We look up your country from your IP address so we can show you UK or US content. We do not keep the result on our servers.
Some of the links we share on social media count how many times they are clicked. We store the number of clicks and nothing about who clicked.
Sensitive information, which needs saying separately
Some of what you tell us is treated as a special category of personal information under UK law. That includes anything about your health, and it may include what you tell us about your circumstances in your application, in the Journey Tool or inside the community.
We handle it on the basis of your explicit consent. We ask for it at the point you first share something: on the application form, in the Journey Tool before your answers are saved, and again when you set up your member account. You can withdraw it at any time by writing to us, and we will delete the information it covered.
In practice this means three things.
You decide what to share. Nothing in the community requires you to write anything. Reading quietly is a normal way to use Opal Circle.
What you write inside stays inside. Our community is closed and every member is vetted. Other members can read what you post in the spaces you share, under the name you chose. We only publish your writing outside the community if you ask us to, and never with your name.
You choose how visible you are. See below.
Your name and how visible you are
We ask for your full name when you apply, because we need to know who you are. On the same form you can give us a different name to appear under in the community. It can be your first name, or a name that is not yours at all. If you leave it blank you appear under your full name, and you can ask us to change that at any time.
There is no public list of members. The member directory inside the community is opt-in, and you start out not listed. Direct messages are switched off until you turn them on, and your email address stays hidden from other members unless you choose to show it.
Nothing about your membership is published, announced, or attached to your name anywhere outside the community unless you ask us to.
We will always know who you are, because we vetted you. Nobody else has to.
Why we hold your information
| What for | Our legal basis |
|---|---|
| Assessing your application, including our conversation with you | To take steps at your request before entering a contract |
| Providing the membership | Performance of our contract with you |
| Sensitive information you share | Your explicit consent |
| Saving your Journey Tool answers | Your explicit consent |
| Introducing you to a professional | Your consent, given each time |
| Sending what you asked for: a guide, your Journey Tool result, sign-in links | Our legitimate interest in giving you what you requested, or our contract with you if you are a member |
| Follow-up and news emails | Your consent, which you can withdraw with one click |
| Assessing and listing professionals, including contacting their referees | Steps before entering a contract, our contract with the professional, and our legitimate interest in assessing anyone we introduce members to |
| Keeping the platform secure and working, including server logs | Our legitimate interests |
| Anonymous statistics from the Journey Tool | Our legitimate interests. Once anonymised, the information is no longer about you |
| Meeting our legal obligations | Legal obligation |
Emails from us
Emails you asked for always arrive. That means the guide you requested, your Journey Tool result, sign-in links, and emails about your application or membership.
Follow-up emails are opt-in. The guide form, the Journey Tool, the application form and account setup each have a box you can tick if you would like occasional emails from us. The box starts unticked. If you leave it that way, you only get what you asked for. Every follow-up email has an unsubscribe link, and unsubscribing takes one click.
If you tick the box, our email provider holds your email address, your first name if you are a member, and enough to keep the emails relevant: whether the guide you chose was about divorce or bereavement, and whether it was written for the UK or the US.
Our newsletter is published on Substack. You subscribe there directly, under Substack's own privacy policy.
Introducing you to a professional
This is the most sensitive thing we do, so it has its own section.
We only ever pass your details to a professional when you have asked us to. We do not share our member list with anybody, and no provider has access to our membership records.
You decide what we pass on. If you agree, that is your first name, how to reach you, and a brief summary of what you would like help with. If you choose to stay anonymous, we tell the professional nothing that identifies you until you have spoken with them. Anything you marked as not to be shared is not shared.
We never tell a provider anything you have written inside the community.
Every provider in our network has signed an agreement that requires them to keep your identity and your circumstances confidential. Once you are working with a professional, they are responsible for the information you give them, under their own privacy policy and professional rules.
We are paid by providers, never by members. We never recommend one professional over another, and a provider cannot pay for a better position or for more introductions. If you would like to know how that arrangement works, ask us and we will tell you plainly.
Who else handles your information
We use a small number of companies to run Opal Circle. They act on our instructions and cannot use your information for their own purposes.
| Company | What it does for us |
|---|---|
| Circle | Runs the community itself: your profile, posts, comments, messages and workshop bookings |
| Brevo | Sends our emails |
| Google Cloud | Runs our servers and private file storage, in London |
| Neon | Hosts our database, in London |
| Vercel | Hosts the website. It sees your IP address, which is how we know whether to show UK or US content |
| Google Workspace | Our team's email and documents. Messages you send us, introduction requests and our notes are held there |
| Calendly | Books your conversation with us |
| Vimeo | Plays our videos, with its tracking switched off |
| Google Sign-In | Only if you choose to sign in with Google |
| Metamindz | The software company that builds and maintains our platform. Its engineers can reach our systems when they need to fix or improve them |
We do not sell your personal information. We do not share it for advertising. We do not give it to anybody who is not either running the platform for us or a professional you have asked to be introduced to.
Our podcast and newsletter links take you to Spotify, Apple, YouTube and Substack. What you do there is covered by their privacy policies, not this one.
Where your information is held
Our database, servers and file storage are in London.
Some of the companies we work with are based in the United States or hold data there. Today those are Circle, Vercel, Calendly, Vimeo and Google, which provides our team's email and documents. That means some information about you is transferred outside the UK. Where that happens, we rely on one of the safeguards UK law recognises. For companies certified under it, that is the UK-US data bridge. For the others, it is the contract terms approved by the Information Commissioner's Office, known as the International Data Transfer Agreement or the UK Addendum. You can ask us which one applies to any company on the list.
Brevo holds data in the European Union, which UK law treats as protecting your information to the same standard as the UK.
How long we keep it
| What | How long |
|---|---|
| If you download a guide, join the early-access list or use the Journey Tool with your email address, and never apply | For as long as you are using Opal Circle. If you have not downloaded a guide, used the Journey Tool, applied or signed in for 24 months, we delete your details |
| Your Journey Tool answers, if you are not an applicant or a member | 24 months after you last used Opal Circle. We then remove your email address and your result link, and keep the answers only in anonymous form |
| While we are considering your application | Until we decide |
| If you are on our waitlist | Until we open where you live, or you ask us to remove you |
| If you apply and are not accepted | 12 months after our decision, so we can see your earlier answers if you apply again. Then deleted, along with our note of the conversation |
| While you are a member | For as long as you are with us |
| After you leave | We close your account straight away. Your profile and posts stay in the community for 6 months and are then deleted, apart from anything we are legally required to keep |
| If you ask us to delete your account | Straight away, including your community profile and everything you posted |
| Records of provider introductions | 6 years |
| A provider application we do not accept | Deleted when we decide, including referees' details |
| A professional in our network | For as long as you are in the network. After you leave, we take your profile down straight away, delete your application details within 12 months, and keep the agreement and payment records for 6 years |
| Messages you send us | 24 months |
| Follow-up emails | Until you unsubscribe. We then keep only your email address on a do-not-email list, so we do not write to you again by mistake |
| Server logs | 30 days |
Your rights
If you are in the UK you have the right to:
- Ask what we hold about you, and get a copy
- Have anything wrong corrected
- Ask us to delete your information
- Ask us to stop or limit what we do with it
- Take your information elsewhere
- Object to how we are using it
- Withdraw consent at any time, without it affecting anything we did before you withdrew it
How to use any of them. Write to us at hello@opalcircle.com or at the address at the end of this policy. We will respond within one month.
Deleting your account. You can ask us to delete everything we hold about you, and we will. Some things may take a little longer to remove entirely from our backups, and we will tell you when that is the case.
If you are unhappy with how we have handled your information, tell us. We will acknowledge your complaint within 30 days and let you know what we have done about it. You can also complain to the Information Commissioner's Office at ico.org.uk. We would rather you came to us first, but you do not have to.
If you are in the United States
We do not sell your personal information, and we do not share it for cross-context behavioural advertising.
Depending on where you live you may have the right to know what we collect, to ask for a copy, to have it corrected or deleted, and not to be treated differently for exercising those rights. Some states also give you the right to limit how we use sensitive personal information.
To exercise any of these, contact us using the details below.
Automated decisions
The Journey Tool produces a suggested stage based on your answers. It is a suggestion, and nothing happens automatically as a result of it. You confirm whether it is right, you can ignore it, and no decision about your membership is made by a computer.
Every application is read by a person and every applicant speaks to a person.
Children
Opal Circle is for adults. We do not knowingly collect information about anybody under eighteen.
Keeping your information safe
Everything you send us is encrypted in transit. Passwords are never stored in readable form, and sign-in links work once and expire within minutes. Our servers, database and files are all hosted in London, and stored data is encrypted. Photos and documents are never at public web addresses. Only a few people on our team have admin access, and deleting an account needs our most senior access.
If something ever goes wrong that puts your information at risk, we will tell you and the Information Commissioner's Office, as the law requires.
Changes to this policy
If we change anything significant, we will tell members directly rather than quietly updating the page. The date at the top shows when this policy last changed.
Contact us
Opal Circle Ltd, 54 Portland Place, London W1B 1DY
For anything about your information, including asking us to delete it, write to us at either address.