Circle Platform Terms

Effective date: 5 June 2026

These Platform Terms govern access to and use of the Global Mobility Circle website, the Circle Deals platform, application and verification flows, and related services provided by Sovium Ltd (registered in England and Wales as SOVIUM LTD, company number 16837739, registered office Bmlg.02, 10 Barley Mow Passage, London, England, W4 4PH) ("Sovium", the "Company", "we", "us", "our"), trading as Global Mobility Circle ("Circle").

Contact: membership@globalmobilitycircle.com

1. Acceptance and scope

1.1 By accessing or using the website, the Circle Deals platform, or any Circle Channel, by completing an application or verification questionnaire, by paying for or holding a membership or subscription, or by attending a Circle event, you agree to these Platform Terms.

1.2 You must not access or use any part of Circle if you do not agree to these Platform Terms.

1.3 These Platform Terms apply to all users of Circle, in any role.

1.4 Role-specific terms. Additional terms apply depending on your role:

if you participate as a Provider, the Provider Terms apply to you;
if you participate as an Agent, the Agent Terms apply to you.

1.5 The Privacy Notice, the Cookie Policy, and the Complaints & Reporting Policy also apply and are incorporated into these Platform Terms by reference.

1.6 If there is any conflict between these Platform Terms and the Provider Terms or Agent Terms, the relevant role-specific terms prevail for matters specific to that role; in all other respects these Platform Terms prevail.

2. Definitions

In these Platform Terms:

Agent — a business user or self-employed professional acting in the course of business who brings client requests and refers cases to Providers through Circle.
Circle — the Global Mobility Circle professional network operated by the Company, including its closed channels and digital infrastructure.
Circle Channels — the closed and controlled environments the Company operates or administers to support Circle activity, including the Circle Deals platform, the Telegram forum, event spaces, and other member communication channels.
Circle Deals — the Company's digital platform on which Members publish Requests, exchange Offers, form and track Deals, hold Partner contacts, and leave Testimonials.
Circle Standards — the membership, conduct, quality, and compliance standards the Company applies to participation in Circle, as updated from time to time.
Deal — an arrangement between Members for the provision of services, formed directly between those Members.
Deal Flow — the feed of open Requests visible to Providers within Circle Deals.
Direct Request — a Request addressed to a specific Provider organisation or to a specific member of a Provider organisation.
Member — a person or organisation admitted to Circle, whether as a Provider or an Agent.
Offer — a structured response submitted by a Provider in reply to a Request.
Partner contacts — contact details that become available to Members in respect of organisations with which they have completed a Deal.
Platform — the Company's website, the Circle Deals platform, and related application, verification, and digital services we operate for membership.
Provider — a verified business that provides global mobility or related professional services and responds to Requests.
Request — a structured client request submitted by a Member through Circle Deals or addressed directly to a Provider.
Testimonial — feedback left by a Member in respect of another Member after a Deal.
User Content — information, text, materials, and feedback you submit, post, upload, or share through the Platform or Circle Channels.

3. Business use only

3.1 The Platform and Circle Channels are offered only for business purposes. You must not use them as a consumer.

3.2 If you are an individual (for example, a self-employed professional), you confirm that you are acting in the course of business and not as a consumer.

4. What Circle is — and is not

4.1 Circle is a vetted professional network and operating environment for the global mobility industry. The Company provides infrastructure, application and verification processes, standards, moderation, events, and the Circle Deals platform that allows Members to publish Requests, exchange Offers, and form Deals with each other.

4.2 The Company is not an immigration, legal, tax, or financial adviser, a broker, an agent, an escrow provider, an employment agency, or a financial intermediary.

4.3 The Company does not provide immigration, legal, tax, or financial advice to you or to your end-clients, and does not guarantee any outcome.

4.4 The Company is not a party to any Deal, transaction, engagement, statement of work, or contract between Members. Members contract independently with each other and with their own clients. All commercial terms — including fees, commission, white-label arrangements, scope, timelines, and deliverables — are agreed directly between the Members concerned. The Company does not negotiate, set, endorse, or guarantee those terms.

4.5 The Company does not handle client funds, escrow, billing, or payments between Members. Payments under a Deal flow directly between the Members and their clients.

4.6 The Company does not charge any commission on Deals. The only amounts payable to the Company are membership and subscription fees, as set out in the Provider Terms and Agent Terms.

5. Controlled access, applications, and accounts

5.1 Access to Circle is controlled. There is no general guest access to Circle Channels.

5.2 Admission typically involves: an application; an introductory call; completion of the verification questionnaire and any requested supporting information; verification; payment (where applicable); approval; and onboarding.

5.3 The Company may approve or refuse any application at its discretion, including for integrity, standards, compliance, or risk-management reasons.

5.4 You are responsible for maintaining the confidentiality of your login credentials and for all activity under your account. You must notify us promptly of any unauthorised use.

5.5 You must ensure that the information you provide is accurate, current, and not misleading, and you must keep it up to date.

6. Verification and "vetted" status

6.1 Verification may include interviews or calls, identity verification through a third-party provider, checks using publicly available information (OSINT), checks against public registers, the use of third-party verification or screening services, and requests for documents or evidence. The specific checks the Company carries out may change over time.

6.2 Verification and "vetted" status reflect the standards and moderation the Company applies. They are not a guarantee of any Member's:

service quality, performance, or deliverables;
licensing or regulatory status in any jurisdiction;
solvency, compliance, or suitability for any particular matter.

6.3 You must carry out your own due diligence before entering into any Deal or sharing any client information.

6.4 The Company may re-review your status at any time if your circumstances change or if it receives information relevant to Circle Standards.

7. Deal Flow, Requests, and dealings between Members

7.1 Through Circle Deals, Members may publish Requests to Deal Flow or address Direct Requests to specific Providers; Providers may respond with Offers; and Members may form Deals directly with each other.

7.2 The Company provides and operates this environment but is not a party to any Request, Offer, or Deal, and does not negotiate, guarantee, or take responsibility for the dealings between Members.

7.3 The Company does not guarantee any number of Requests, Offers, Deals, response times, or outcomes.

7.4 You are solely responsible for compliance with all laws, professional regulations, and duties applicable to your activities, including client confidentiality, conflicts of interest, anti-money-laundering, sanctions, and marketing rules.

8. Confidentiality and closed-network obligations

8.1 Circle is a closed professional environment. You must keep confidential and must not disclose, publish, distribute, or otherwise make available any non-public Circle information, including:

the non-public identity, contact details, or participation of Circle participants;
content from Circle Channels;
Requests, Offers, Deals, and related communications;
case details or end-client information shared with you;
internal moderation decisions or internal reputation signals that are not publicly disclosed.

8.2 You must not create, replicate, or help create any directory, database, or catalogue of Circle participants.

8.3 You must not scrape, harvest, export, copy, compile, or systematically collect participant data or contact details from the Platform or Circle Channels.

8.4 You must not share screenshots, transcripts, or recordings of Circle communications without prior written permission.

8.5 Handling of end-client information. You must keep end-client information confidential and share it only with Members who have a legitimate need to know in connection with a specific Request, and only where you have lawful authority to do so. You must minimise the end-client personal data you enter into the Platform: do not enter end-client names or other directly identifying personal data into Requests, and conduct the exchange of identifying details and supporting documents off-platform unless and until the Company provides a dedicated secure feature for that purpose.

9. Acceptable use, conduct, and content

9.1 You must use the Platform and Circle Channels lawfully, professionally, and in accordance with Circle Standards, moderation decisions, and these Platform Terms.

9.2 You must not:

use the Platform for any unlawful purpose or to facilitate any unlawful activity;
post, upload, or share any content that is unlawful, infringing, defamatory, harassing, abusive, threatening, discriminatory, or that violates any third party's rights or confidentiality;
impersonate any person or misrepresent your identity, credentials, or authority;
send spam or unsolicited promotions;
introduce malware, attempt to breach security, or interfere with the operation of the Platform.

9.3 Unsolicited advertising or promotions inside Circle Channels and Circle events are prohibited unless expressly approved by the Company in writing.

9.4 Reporting and removal. If you become aware of content on the Platform that is unlawful or breaches these Platform Terms, you can report it as described in the Complaints & Reporting Policy. The Company may review, restrict, or remove User Content, and may restrict or suspend access, where necessary to protect Circle, enforce Circle Standards, address unlawful content or abuse, or comply with legal obligations.

10. Reputation signals, feedback, and Testimonials

10.1 The Company may track interaction signals and Member feedback, including Testimonials, to support network quality, trust, and moderation.

10.2 Reputation signals are informational and discretionary. They do not constitute an endorsement, certification, or guarantee by the Company.

10.3 A Testimonial reflects the view of the Member who gave it and is attributed to the parties to the relevant Deal at the time it closed.

11. Optional programmes

11.1 The Company may offer optional programmes, including referral initiatives, to eligible Members. Any such programme is governed by its own terms.

11.2 The Company may change, suspend, or withdraw any such programme. Changes apply prospectively.

11.3 Participation in any programme does not change the Company's role as platform operator and does not create any brokerage, agency, partnership, or fiduciary relationship.

12. Fees, subscriptions, renewals, and refunds

12.1 The fees and payment terms for membership and subscriptions are set out in the Provider Terms and the Agent Terms. Fees are stated in euros (EUR) and are processed by our payment provider, Stripe. Where agreed in writing, the Company may accept payment by invoice or bank transfer.

12.2 Auto-renewal. Paid subscriptions renew automatically at the end of each subscription period at the then-current fee for the applicable plan, unless cancelled before the renewal date. By taking out a paid subscription, you authorise the Company (through Stripe) to charge the applicable renewal fee.

12.3 Cancellation. You may cancel auto-renewal at any time before the next renewal date, as described in the Provider Terms or Agent Terms. Cancellation stops the next renewal charge. Your access continues until the end of the period you have already paid for, and is not extended or refunded.

12.4 No refunds. Except as set out in clause 12.5, all fees are non-refundable. There are no refunds, credits, or pro-rata adjustments for unused time, early cancellation, suspension, or termination.

12.5 Refund on refused admission. If you pay a subscription fee in advance and the Company then refuses your admission following verification, the Company will refund that fee, subject to reasonable fraud and compliance checks. This is the only circumstance in which a fee is refundable, other than where a refund is required by law.

12.6 Taxes. Fees are exclusive of any applicable taxes, which are handled as set out in the Provider Terms or Agent Terms. Payment-processing fees charged by the payment provider are borne by the Company. If any deduction or withholding is required by law on a payment to the Company, you remain responsible for ensuring the Company receives the full invoiced amount, unless prohibited by law.

13. Intellectual property and brand

13.1 The Platform, its design, text, and all Company-created materials are protected by intellectual-property rights. You receive no ownership in them.

13.2 You must not use "Global Mobility Circle", "Circle", "Circle Deals", the Company logo, or any Company branding in a way that suggests endorsement, partnership, or affiliation, without prior written permission, except where the Company expressly permits factual member references.

13.3 If you provide a Testimonial, logo, or similar material for publication, you grant the Company permission to publish and use it for that purpose.

14. User Content licence and responsibility

14.1 You retain ownership of your User Content.

14.2 You grant the Company a non-exclusive, worldwide, royalty-free licence to host, store, display, reproduce, and process your User Content to:

operate and provide the Platform and Circle services;
administer applications and verification;
enable Requests, Offers, Deals, and communications;
maintain records for compliance and dispute handling.

14.3 You are responsible for ensuring that your User Content is accurate and lawful, and does not infringe any third party's rights or confidentiality. You confirm that you have the right to grant the licence in clause 14.2.

15. Data protection

15.1 The Company processes personal data in accordance with its Privacy Notice.

15.2 You confirm that you have a lawful basis and the authority to share any personal data of third parties (including end-client data) that you provide to Circle participants or process through Circle, and that you will share only what is necessary, consistent with clause 8.5.

16. Sanctions and compliance

16.1 The Company may restrict or refuse access where necessary for compliance with applicable laws, sanctions, export controls, or risk management.

16.2 You represent and warrant that your participation in Circle and your activities in connection with the Platform comply with applicable sanctions laws and regulations and applicable anti-money-laundering and anti-bribery laws, and that you will not use Circle to facilitate sanctions evasion, money laundering, terrorist financing, or any other unlawful activity. Further compliance warranties applicable to your role are set out in the Provider Terms or Agent Terms.

17. Suspension and termination

17.1 The Company may suspend or terminate your access immediately where necessary to protect Circle, its participants, or the Platform, or to comply with law.

17.2 The Company may suspend or terminate your access where you are in serious or repeated breach (including breaches of confidentiality or closed-network obligations), where you no longer meet Circle Standards, or where continued participation presents unacceptable risk to Circle.

17.3 The Company may also suspend or terminate access if it discontinues the relevant service or transitions to a new product model, subject to any mandatory legal requirements.

17.4 Suspension or termination does not create any right to a refund, except as set out in clause 12.

18. Disclaimers

18.1 The Platform and Circle services are provided "as is" and "as available".

18.2 The Company does not warrant uninterrupted or error-free availability, or that participation will generate Requests, Offers, Deals, revenue, or any specific outcome.

18.3 The Company does not endorse or guarantee any Member's services, statements, or deliverables, and is not responsible for their acts or omissions.

19. Limitation of liability

19.1 Nothing in these Platform Terms limits or excludes liability for death or personal injury caused by negligence, for fraud or fraudulent misrepresentation, or for any other liability that cannot be limited or excluded by law.

19.2 Subject to clause 19.1, the Company is not liable for:

indirect or consequential losses;
loss of profit, revenue, goodwill, or business opportunity;
disputes between Members;
losses arising from services provided by Members or third parties.

19.3 For the avoidance of doubt, this clause limits exposure for claims and does not create any right to refunds or credits. Refunds (if any) are governed exclusively by clause 12 and by the Provider Terms or Agent Terms.

19.4 Subject to clause 19.1, the Company's total aggregate liability arising out of or in connection with these Platform Terms is limited to the fees paid by you to the Company in the twelve months immediately preceding the event giving rise to the claim.

20. Changes to these Platform Terms

20.1 The Company may update these Platform Terms to reflect operational, legal, or risk requirements.

20.2 The Company will communicate material changes by email and/or by a prominent notice on the Platform.

20.3 Your continued use after the effective date of the updated Platform Terms constitutes acceptance.

21. Governing law and jurisdiction

21.1 These Platform Terms and any dispute or claim arising from them are governed by the laws of England and Wales.

21.2 The courts of England and Wales have exclusive jurisdiction, subject to any mandatory rules that cannot be excluded.

22. Company details

Sovium Ltd (registered in England and Wales as SOVIUM LTD) Company number: 16837739 Registered office: Bmlg.02, 10 Barley Mow Passage, London, England, W4 4PH Contact: membership@globalmobilitycircle.com