Circle Advocates Terms & Conditions
Program Agreement
This Circle Advocates Program Agreement ("Agreement") is entered into between Circle Surrogacy, LLC, using the applicable contracting legal entity identified by Circle ("Circle"), and the undersigned participant ("Advocate"). By signing this Agreement, the Advocate agrees to participate in the Circle Advocates Program ("Program") subject to this Agreement, the Circle Ambassador Code of Conduct, and other Program policies incorporated by reference.
1. Program Purpose
The Program supports education, advocacy, relationship-building, and community engagement relating to surrogacy and family building. The Program encourages authentic conversations, responsible information sharing, and positive community participation while supporting Circle's mission of helping families grow.
2. Eligibility and Enrollment
Participation is subject to Circle approval. To participate, an individual must:
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Be at least 18 years old;
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Complete the Program application and required one-on-one Welcome Call;
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Complete required training and acknowledgments;
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Agree to the Circle Ambassador Code of Conduct and this Agreement; and
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Remain in good standing under current Program requirements.
Circle may approve, deny, suspend, or terminate participation in accordance with this Agreement and applicable law.
3. Nature of Relationship and Authority
Participation is voluntary. The Advocate is not a Circle employee, agent, partner, joint venturer, spokesperson, or legal representative, and has no authority to bind Circle, enter into agreements on Circle's behalf, or make commitments for Circle.
Nothing in this Agreement guarantees hours, assignments, referral volume, compensation, employment benefits, or continued participation. The Advocate is responsible for personal tax obligations arising from payments received and agrees to provide any tax documentation reasonably requested by Circle. Circle may issue tax reporting forms when required by law.
4. Advocate Responsibilities
The Advocate agrees to:
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Participate authentically and treat others respectfully;
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Complete required onboarding and training;
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Follow this Agreement, the Code of Conduct, and current Program policies;
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Share accurate information and speak only from personal knowledge or experience;
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Use approved Circle resources when discussing Program or service details;
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Protect confidential and personal information;
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Follow applicable laws, endorsement rules, and platform or community policies; and
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Promptly correct or remove Program-related content when reasonably requested for legal, safety, accuracy, privacy, or compliance reasons.
5. Training, Portal Access, and Program Resources
Portal access is granted only after the Advocate has successfully completed the Program application, Welcome Call, execution of this Agreement, and any additional onboarding requirements communicated by Circle.
Circle may add, modify, restrict, or remove training requirements, portal features, resources, community access, participation requirements, or Program benefits at any time.
Advocates must remain in good standing and comply with this Agreement, the Circle Ambassador Code of Conduct, and Program policies to maintain portal access.
An Advocate who does not generate at least one qualified referral within a six-month period may be designated as inactive. Inactive Advocates may lose access to certain Program benefits, portal features, rewards, referral incentives, community privileges, or participation opportunities as described in current Program materials.
Circle reserves the right to suspend, restrict, or terminate portal access for inactivity, failure to meet Program requirements, or violation of this Agreement, the Code of Conduct, or any applicable Program policy.
Former Advocates who wish to participate in the Program after removal or inactivity may be required to reapply, complete current onboarding requirements, and satisfy eligibility requirements then in effect.
6. Referral Submission and Attribution
Referral credit is available only for referrals submitted through the Advocate's unique Circle-approved referral link. Referrals submitted through any other method may not be eligible for rewards, bonuses, incentives, or other Program benefits.
Prospective surrogates or other interested individuals must voluntarily submit their own information directly to Circle through the Advocate's referral link. Advocates may not submit referral information on behalf of another individual.
A referred individual may be ineligible for attribution if already known to or engaged with Circle, previously submitted through another source, credited to another referral source, or otherwise deemed ineligible under current Program rules.
Circle will review duplicate, disputed, incomplete, overlapping, or potentially fraudulent referrals and will determine attribution in good faith using available records. Circle's determination regarding referral attribution, eligibility, qualification, and reward eligibility shall be final to the extent permitted by law.
7. Rewards, Incentives, and Taxes
Circle may offer referral compensation, incentives, bonuses, contests, recognition, status levels, or other benefits. Current reward opportunities, qualification requirements, participation standards, eligibility rules, and payment schedules are maintained separately in Program materials and may be modified from time to time.
Eligibility for any reward or benefit is conditioned upon compliance with this Agreement, the Code of Conduct, current Program rules, verified referral attribution where applicable, and completion of any stated qualifying event.
Certain rewards, incentives, bonuses, compensation levels, or referral benefits may be conditioned upon maintaining active participation status, as defined in current Program materials.
Participation does not guarantee referrals, compensation, earnings, bonuses, rewards, opportunities, status levels, or future benefits of any kind.
The Advocate is solely responsible for any personal tax obligations arising from rewards, compensation, bonuses, or incentives received through the Program.
8. Right to Modify or Discontinue the Program and Rewards
To the extent permitted by applicable law, Circle may modify, suspend, replace, or discontinue any Program requirement, referral process, qualification criterion, training item, portal feature, reward, payment structure, incentive, bonus, contest, status level, recognition opportunity, or other Program benefit. Circle may also suspend or discontinue the Program.
Changes will apply prospectively after notice through the Program portal, email, updated Program materials, or another reasonable method. Unless required by law or stated otherwise in the applicable Program terms, a change will not reduce a payment that was already earned and approved after completion of the applicable qualifying event under the terms then in effect. Participation does not create a vested right to future compensation, rewards, bonuses, status, benefits, or opportunities.
9. FTC Disclosures and Endorsements
The Advocate understands that eligibility for compensation, rewards, or other benefits may create a material connection with Circle. Whenever that connection could affect how an audience evaluates a public endorsement, recommendation, testimonial, or Circle-related message, the Advocate must make a clear and conspicuous disclosure in the message itself, in a manner that is easy to notice and understand.
The Advocate agrees to:
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Disclose the Advocate relationship in Circle-related public content when required;
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Place disclosures where they are difficult to miss and in the same language as the message;
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For video or live content, use disclosures appropriate to the format and repeat them when reasonably necessary;
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Share only honest opinions and actual experiences;
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Avoid false, misleading, deceptive, or unsubstantiated statements;
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Avoid representing personal opinions as official Circle positions; and
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Avoid implying guaranteed or typical medical, legal, financial, matching, compensation, or journey outcomes.
Examples such as “Circle Advocate,” “I’m a Circle Advocate and may receive referral rewards,” or another disclosure approved by Circle may be used when accurate and sufficiently clear for the context. A hashtag alone may not be sufficient in every format or placement. Circle may require correction, additional disclosure, or removal of content that reasonably raises legal or compliance concerns.
10. Communication Boundaries
The Advocate may share personal experiences, general educational information, and approved Circle resources. The Advocate may not provide or present as Circle-authorized medical, mental health, legal, tax, insurance, eligibility, contract, or financial advice; promise outcomes; quote unapproved or outdated Program terms; or speak to media on Circle’s behalf. Questions requiring individualized guidance must be referred to Circle or an appropriate qualified professional.
Circle reserves the right, in its sole discretion, to immediately suspend or terminate an Advocate from the Program if Circle determines that the Advocate’s community conduct, online behavior, or social media presence does not align with Circle’s core values, mission, or ethical standards.
11. Confidentiality and Privacy
The Advocate may receive confidential, proprietary, sensitive, or non-public information about Circle, applicants, surrogates, intended parents, clients, employees, Program participants, operations, or business practices ("Confidential Information"). The Advocate will use Confidential Information only for authorized Program purposes, protect it from unauthorized access or disclosure, and not share personal or identifying information about another person without authorization.
Confidential Information does not include information that the Advocate can document was lawfully public through no breach of this Agreement, lawfully received without a duty of confidentiality, or independently developed without using Circle Confidential Information. If disclosure is legally required, the Advocate will provide prompt notice to Circle when legally permitted and disclose only what is required. These obligations survive termination.
12. Data Privacy
The Advocate acknowledges that in connection with the Program, they may become aware of, or have access to, highly sensitive personal and medical information regarding prospective surrogates, intended parents, or children (collectively, “Protected Information”). The Advocate agrees to comply with all applicable state and federal privacy laws, including, where applicable, the Health Insurance Portability and Accountability Act (“HIPAA”). The Advocate shall not:
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Request, collect, retain, or transmit any clinical, medical, or psychological histories of referred individuals.
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Publicly disclose, post, or share any individual’s specific medical information or personal health journey without explicit, written authorization from both the individual and Circle.
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Use any Protected Information obtained through the Program for any purpose other than facilitating the initial referral link.
13. Circle Materials and Intellectual Property
Circle owns or licenses its names, logos, trademarks, graphics, videos, templates, training materials, social assets, and other Program content. Circle grants the Advocate a limited, non-exclusive, non-transferable, revocable permission to use approved materials solely for authorized Program participation. The Advocate may not materially alter, sublicense, sell, or use Circle materials outside the Program without written permission. Permission ends when participation ends, or Circle requests that use stop.
14. Advocate Content; Name, Image, and Testimonials
If Advocate voluntarily submits content, photos, videos, quotes, testimonials, stories, social media posts, or other materials to Circle for Program use, the Advocate grants Circle, its affiliates, subsidiaries, parent companies, successors, assigns, contractors, service providers, marketing partners, and agents a non-exclusive, worldwide, royalty-free, transferable, sublicensable license to reproduce, edit for length or format without changing meaning, publish, display, distribute, share, promote, and otherwise use such submitted materials for educational, recruiting, promotional, community, advocacy, marketing, advertising, training, public relations, and other Program-related purposes.
The Advocate acknowledges and agrees that submitted materials may be displayed, shared, or made available within the Circle Advocates Portal, community forums, training materials, educational resources, promotional materials, websites, social media channels, presentations, publications, and other Program-related content accessible to Circle personnel, affiliated companies, authorized vendors, partners, other Program participants, and other authorized third parties.
The Advocate understands and agrees that materials submitted for Program use may be incorporated into community resources, training materials, educational content, marketing materials, or other Program assets that may continue to be used by Circle, its affiliates, and other Program participants.
The Advocate represents that the Advocate has the right to provide submitted material and that it does not disclose another person's confidential, proprietary, or private information.
The Advocate may withdraw permission for new uses by written notice; however, such withdrawal shall not require Circle, its affiliates, vendors, partners, or other Program participants to remove, recall, delete, modify, discontinue, or cease using materials that were previously published, distributed, shared, incorporated into Program materials, community resources, training materials, promotional content, or other existing uses prior to receipt of the withdrawal notice.
15. Prohibited Conduct and Indemnification
The Advocate may not engage in fraud, deceptive or coercive recruiting, harassment, discrimination, unauthorized financial solicitation, misuse of personal data, impersonation, confidentiality breaches, false claims, manipulation of referrals, or conduct that violates the Code of Conduct, law, platform rules, or community guidelines.
The Advocate agrees to defend, indemnify, and hold harmless Circle, its affiliates, officers, directors, employees, and agents from and against any and all claims, liabilities, damages, losses, costs, or expenses (including reasonable attorneys’ fees) arising out of or resulting from:
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Advocate’s breach or alleged breach of this Agreement, the Code of Conduct, or incorporated Program policies;
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Any negligent acts, omissions, or willful misconduct by the Advocate in connection with their participation in the Program;
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Any false, deceptive, misleading, or unauthorized statements made by the Advocate regarding Circle, its services, compensation structures, or the Program; or
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Advocate’s failure to comply with applicable laws and regulations, including but not limited to Federal Trade Commission (FTC) disclosure guidelines and data privacy regulations.
Circle reserves the right, at its own expense, to assume the exclusive defense and control of any matter otherwise subject to indemnification by the Advocate, in which event the Advocate will cooperate fully with Circle in asserting any available defenses.
16. Suspension and Termination
Either party may end participation at any time by written notice. Circle may immediately restrict access, suspend, or terminate participation for a suspected or confirmed violation, fraud, confidentiality or privacy concern, unsafe conduct, noncompliance with disclosure rules, misuse of Circle materials, reputational harm, inactivity as described in current Program materials, or other material Program concern.
Upon termination, the Advocate must stop representing an active relationship with Circle, stop using Circle materials, and return or delete Confidential Information as directed. Sections intended by their nature to survive, including confidentiality, intellectual property restrictions, payment obligations for amounts properly earned and approved, governing law, and general terms, will survive.
17. No Guarantee; Release of Program Expectations
Circle does not guarantee the availability, continuity, profitability, reach, or success of the Program; any referral outcome; acceptance, matching, medical or legal clearance; or any level of earnings. The Advocate makes personal participation decisions independently and at the Advocate’s own discretion.
18. Governing Law and Forum
This Agreement and any dispute arising out of or relating to this Agreement shall be governed by and construed in accordance with the laws of the Commonwealth of Massachusetts, without regard to conflict-of-law principles.
Subject to any mandatory law or separately agreed dispute-resolution procedure, the parties agree that any legal action arising out of or relating to this Agreement shall be brought exclusively in the state or federal courts located within the Commonwealth of Massachusetts.
19. Notices
Program notices may be provided by email, through the Program portal, or another reasonable electronic method using the contact information on file. Notices from the Advocate to Circle must be sent to advocatessupport@circlesurrogacy.com. Each party is responsible for keeping its contact information current.
The Advocate agrees that Circle may contact the Advocate regarding the Program, Circle services, opportunities, updates, reminders, marketing communications, and related information by email, SMS/text message, phone, Program portal message, and other electronic or marketing channels using the contact information provided. Message and data rates may apply. The Advocate may opt out of marketing communications where required by law, but agrees that Circle may continue to send transactional, administrative, or Program-related communications necessary for participation in the Program.
20. General Terms
This Agreement, the Code of Conduct, and incorporated Program policies constitute the agreement between the parties regarding Program participation and supersede prior discussions on that subject. If a conflict exists, this Agreement controls unless a later written policy expressly states otherwise.
If any provision is found unenforceable, it will be modified to the minimum extent necessary or severed, and the remaining provisions will remain effective. A waiver must be in writing and applies only to the specific instance. The Advocate may not assign this Agreement or Program status without Circle’s written consent. Circle may assign this Agreement in connection with a merger, reorganization, sale, or transfer of the Program or relevant business. Electronic signatures and counterparts are effective as originals.
21. Electronic Acceptance and Acknowledgment
By checking the acceptance box and submitting the applicable Circle enrollment, onboarding, portal registration, or Program participation form, the Advocate acknowledges and agrees that:
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The Advocate has read, understands, and agrees to be bound by this Agreement;
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The Advocate has received or can access the Circle Ambassador Code of Conduct and current Program policies;
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The Advocate agrees to complete required onboarding and training;
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The Advocate understands that Program compensation, rewards, bonuses, incentives, and qualification requirements are maintained separately and may change prospectively;
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The Advocate understands that referral credit is available only through the Advocate's unique Circle-approved referral link;
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The Advocate understands that prospective referrals must submit their own information directly through that referral link;
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The Advocate understands that certain Program rewards, incentives, or compensation opportunities may depend upon maintaining active participation status under current Program requirements;
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The Advocate understands and agrees to comply with FTC disclosure and communication requirements;
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The Advocate has had the opportunity to review this Agreement and ask questions before accepting it;
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The Advocate's electronic acceptance shall have the same force and effect as a handwritten signature.
Rewards and Qualification Guide
1. Program Overview
The Circle Advocates Program recognizes individuals who educate prospective surrogates and connect them with Circle through approved referral activities.
This Guide explains participant classifications, referral rewards, milestone definitions, bonus opportunities, participation requirements, payment timing, and qualification requirements.
Participation and payment eligibility are subject to the:
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Circle Advocates Program Agreement
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Circle Advocates Code of Conduct
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Social Media & FTC Disclosure Guidelines
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Required onboarding and training materials
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Other current Program Policies and communications
These materials are incorporated into and form part of the Circle Advocates Program requirements.
2. Participant Classifications
Active Circle Advocate
An Active Circle Advocate is a participant, including a former Circle surrogate participating as an Advocate, who completes all onboarding requirements, receives portal access, remains in good standing, and satisfies the rolling six-month activity requirement described in this Guide.
Connector
A Connector is an individual who wishes to make an occasional or one-time referral, is not actively participating as an Advocate, or no longer satisfies Active Advocate requirements.
Connectors remain valued Program participants, receive Connector-level referral rewards, and are not eligible for Advocate-specific bonuses unless Active Advocate Status is reinstated.
3. Referral Reward Structure
Active Circle Advocates
Milestone | Reward |
|---|---|
Referral Accepted by Circle | $500 |
Referral Matched | $500 |
Referral Medically & Legally Cleared | $2,000 |
Total Potential Reward Per Referral | $3,000 |
Connectors
Milestone | Reward |
|---|---|
Referral Accepted by Circle | $500 |
Referral Matched | $500 |
Referral Medically & Legally Cleared | $500 |
Total Potential Reward Per Referral | $1,500 |
Each milestone is earned separately after Circle confirms that the milestone and all current Program requirements have been satisfied.
4. Reward Milestone Definitions
Referral Accepted by Circle
A referral is considered Accepted by Circle when the prospective surrogate:
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Submits her information through the approved referral process;
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Completes Circle's required prescreening and screening requirements;
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Completes the Surrogacy Consultation with a licensed mental health professional;
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Completes the required psychological assessment;
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Successfully satisfies Circle's then-current eligibility requirements; and
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Is formally approved by Circle to move forward in the matching process.
Milestone Reward: $500
Referral Matched
A referral is considered Matched when:
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The approved surrogate and intended parent(s) have mutually agreed to move forward together;
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Circle has formally confirmed the match;
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Preliminary clinical approval has been granted;
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The match has progressed into the medical and legal phase of the surrogacy journey.
Milestone Reward: $500
Referral Medically & Legally Cleared
A referral is considered Medically & Legally Cleared when Circle confirms that:
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All required medical screening, evaluations, and clearance requirements have been completed;
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The surrogate has been medically approved to proceed;
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All required legal requirements have been satisfied; and
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The surrogate and intended parent(s) have executed a fully signed and legally binding surrogacy agreement.
Milestone Reward: Active Circle Advocate: $2,000; Connector: $500
Milestone Determination
Circle retains sole discretion to determine when a referral has achieved a milestone and satisfies current Program requirements for payment eligibility.
5. Referral Tracking and Qualification Rules
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The prospective surrogate must submit her own information through the participant's unique Circle-approved referral link or other approved tracking method.
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Participants may not submit information on behalf of another person.
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Referral credit cannot be transferred or applied retroactively.
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Participants may not refer themselves.
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Rewards are not available for individuals already known to Circle, already included within Circle records, or already engaged in Circle's screening process before submission through the approved referral process.
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Rewards are available only for eligible and properly tracked referrals.
Duplicate Referral Claims
If multiple participants claim the same referral, referral credit will be awarded based upon the approved referral link or approved tracking method used when the prospective surrogate submitted her information.
Circle's referral tracking records will control in the event of a dispute.
6. Initial Advocate Qualification
A participant who has:
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Submitted and received approval of the Circle Advocate application;
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Accepted the Circle Advocates Program Agreement and related Program Policies;
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Completed the required Welcome Call and onboarding requirements; and
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Received access to the Circle Advocate portal
will be provisionally eligible for the Active Advocate reward structure during the participant's initial rolling six (6) month activity period.
If the participant achieves at least one (1) Accepted Referral during that initial period, the participant will maintain Active Advocate Status.
If the participant does not achieve at least one (1) Accepted Referral during that initial period, Circle may reclassify the participant as a Connector for future referrals.
The first qualifying referral made during the initial six-month period is eligible for the Active Advocate reward structure, subject to all Program requirements.
7. Active Advocate Status and Rolling Six-Month Activity Requirement
A participant is considered an Active Advocate only after all of the following requirements have been satisfied:
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Submission and approval of the Circle Advocate application;
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Acceptance of the Circle Advocates Program Agreement and related Program Policies;
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Completion of the required Welcome Call and onboarding requirements;
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Receipt of access to the Circle Advocate portal; and
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Achievement of at least one (1) Accepted Referral during each rolling six (6) month period.
Rolling Six-Month Activity Requirement
Active Advocate Status is reviewed on an ongoing basis.
An Active Advocate must have at least one (1) Accepted Referral during the immediately preceding six (6) months.
The initial six (6) month period begins on the date the participant receives access to the Circle Advocate portal.
Reclassification Notice
Circle will notify a participant of reclassification to Connector status.
Reclassification becomes effective on the date identified in Circle's notice and applies to referrals submitted on or after that effective date.
Circle may waive, extend, or modify an activity requirement on a case-by-case basis in its sole discretion.
8. Reinstatement and Existing Referrals
A Connector may be considered for reinstatement as an Active Circle Advocate after achieving one (1) Accepted Referral and satisfying current Program requirements.
Compensation Following Reinstatement
The Accepted Referral that satisfies the reinstatement requirement will be compensated under the Connector reward structure.
The Active Advocate reward structure and bonus eligibility will apply only to qualifying referrals submitted after Circle confirms reinstatement in writing.
Existing Referrals
A referral submitted while a participant held Active Advocate Status will continue under the reward structure that applied on the submission date, provided the referral was properly tracked, and the participant remains compliant with Program requirements.
Reclassification does not reduce rewards already earned and approved.
9. Consistency Bonus
Active Circle Advocates may earn cumulative Consistency Bonuses based on Accepted Referrals achieved during the applicable rolling twelve (12) month bonus period.
Accepted Referrals | Bonus |
|---|---|
3 Accepted Referrals | $500 |
6 Accepted Referrals | $1,000 |
9 Accepted Referrals | $1,500 |
12 Accepted Referrals | $2,500 |
Each threshold bonus may be earned once during the applicable period.
Total Potential Consistency Bonuses: $5,500
Bonus Threshold Eligibility
Each Consistency Bonus threshold may be earned only once for the same group of Accepted Referrals.
Accepted Referrals previously used to qualify for a threshold bonus may continue counting toward higher threshold bonuses, but the same threshold bonus will not be paid again solely because those referrals remain within a later rolling twelve (12) month calculation.
10. Achievement Bonus
An Active Circle Advocate who achieves:
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Twelve (12) Accepted Referrals; and
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Six (6) Matched Referrals
within the same applicable rolling twelve (12) month period may qualify for a one-time Achievement Bonus of $5,000.
This bonus is separate from the Consistency Bonus.
The Achievement Bonus may be earned only once during a rolling twelve-month period in the Circle Advocates Program.
11. Rolling Twelve-Month Bonus Period
Eligibility for the Consistency Bonus and Achievement Bonus is reviewed on a rolling twelve (12) month basis by counting qualifying milestones achieved during the immediately preceding twelve (12) months.
The participant's initial measurement period begins on the date access to the Circle Advocate portal is provided.
Only referrals that achieve Accepted Referral status during the applicable rolling twelve (12) month period will count toward bonus qualification.
The rolling six (6) month activity requirement for Active Advocate Status is separate from the rolling twelve (12) month bonus period.
12. Earned and Approved Rewards
A reward is earned only when Circle verifies that the applicable milestone and all Program requirements have been satisfied.
A reward is approved when Circle confirms the applicable payment amount for processing.
Submission of a referral or progress toward a milestone does not create an earned or approved payment.
13. Good Standing, Payment, and Taxes
The participant must be in good standing, in Circle’s sole discretion, when a reward or bonus is paid.
Payments will be issued within forty-five (45) days after the applicable milestone or bonus event occurs and is verified by Circle using the payment method designated by Circle.
Payments remain subject to referral tracking, milestone verification, participant classification, compliance review, required documentation, and Program eligibility requirements.
Taxes and Payment Documentation
Participants are responsible for any applicable tax obligations arising from Program payments.
Circle may require completion of applicable payment and tax documentation before issuing a payment.
A delay caused by missing, incomplete, or inaccurate participant documentation will not constitute a failure by Circle to meet the standard payment-processing timeframe.
14. Ineligible, Adjusted, Revoked, or Recovered Payments
Circle may withhold, adjust, revoke, or recover a payment when:
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The payment was issued in error;
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The payment was duplicated;
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The payment was based on inaccurate or fraudulent information; or
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The payment was connected to conduct that violated Program requirements applicable to that payment.
Circle may also determine that a referral, reward, or bonus is ineligible when Program requirements have not been satisfied.
15. Voluntary Withdrawal and Program Termination
A participant may discontinue participation at any time by notifying the Circle Advocates Team.
Circle may suspend, restrict, or terminate participation in its sole discretion and as permitted by the Program Agreement, Code of Conduct, social media & FTC Disclosure Guidelines, and other Program Policies.
The treatment of pending or previously submitted referrals will be determined in accordance with the reward structure and Program requirements applicable to those referrals.
16. Program Changes and Final Authority
Circle may prospectively modify, suspend, replace, or discontinue reward amounts, bonus opportunities, qualification requirements, activity requirements, participant classifications, payment schedules, or other Program incentives.
Changes will not affect rewards already earned and approved before the effective date of the change unless otherwise required by law.
Circle retains sole and final discretion regarding:
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Referral qualification;
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Milestone achievement;
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Payment eligibility;
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Bonus eligibility;
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Participant classification;
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Reinstatement decisions;
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Duplicate referral disputes;
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Referral tracking records; and
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Interpretation of Program requirements.
17. No Employment or Guaranteed Income
Participation does not create an employment relationship, agency relationship, partnership, or joint venture.
Rewards and bonuses are not wages, salaries, commissions, or guaranteed income.
No referral, milestone, payment, or bonus is guaranteed.
18. Related Program Materials and Questions
Related Program Materials include:
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Circle Advocates Program Agreement
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Circle Advocates Code of Conduct
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Social Media & FTC Disclosure Guidelines
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Required onboarding and training materials
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Other current Program Policies and communications
Questions regarding participant status, referral tracking, qualification requirements, payment eligibility, rewards, or bonuses should be directed to the Circle Advocates Team through the current Program contact method.
Code of Conduct
As a Circle Advocate, you play an important role in helping individuals and families learn about surrogacy through authentic experiences, shared knowledge, and supportive conversations.
This Code of Conduct is designed to protect the trust, integrity, and sense of community that make Circle Advocates special, while outlining the standards expected of all Advocates.
Section 1. The Advocate Promise
As a Circle Advocate, I agree to:
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Lead with kindness, honesty, and respect.
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Share my experiences authentically.
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Support others without pressure or judgment.
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Respect that every surrogacy and family-building journey is unique.
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Help create spaces where questions are welcomed and supported.
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Protect the privacy and dignity of others.
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Represent Circle in a way that reflects our values of education, connection, and support.
Section 2. Information Sharing Standards
Advocates May
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Share their personal surrogacy, parenthood, or family-building experiences.
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Direct individuals to Circle resources, websites, and team members.
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Share approved Circle content, graphics, and educational materials.
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Discuss surrogacy and family building in general terms.
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Share information about Circle Advocates rewards and opportunities using current approved Program materials and required disclosures.
Advocates May Not
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Share confidential information about another person.
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Provide medical, legal, tax, financial, insurance, mental health, or other professional advice.
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Guarantee compensation, eligibility, matching timelines, approvals, or outcomes.
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Misrepresent Circle policies, services, rewards, or Program requirements.
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Present personal opinions as official Circle positions.
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Submit referral information on behalf of another person.
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Represent themselves as a Circle employee, spokesperson, or authorized representative unless specifically approved by Circle.
Section 3. Community and Social Media Standards
Advocates are expected to conduct themselves respectfully in all public and private interactions related to Circle, including on social media, websites, online groups, forums, events, and community spaces.
Advocates Must
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Clearly disclose their Circle Advocate relationship when required.
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Use respectful and inclusive language.
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Follow the rules of any platform, group, or community in which they participate.
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Engage in discussions constructively and responsibly.
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Refer media inquiries directly to Circle.
Advocates May Not
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Harass, intimidate, bully, threaten, or attack others.
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Engage in public arguments on behalf of Circle.
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Make false, misleading, defamatory, or disparaging statements about Circle, another surrogacy agency, fertility clinic, family-building organization, intended parent, surrogate, Advocate, or other individual.
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Compare agencies using unverified claims, inaccurate information, or misleading statements.
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Engage in public disputes with representatives of another agency or organization.
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Post misleading, deceptive, or intentionally false information.
Advocates should focus on sharing accurate information about their own experiences and the benefits of Circle rather than criticizing, attacking, or making unsupported comparisons about another agency or organization.
Section 4. Privacy and Confidentiality
Surrogacy and family building are deeply personal experiences. Advocates are expected to respect the privacy of all individuals.
Advocates must not:
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Share names, identifying information, photos, medical details, or personal circumstances of another individual without appropriate permission.
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Share confidential, proprietary, sensitive, or non-public Circle information.
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Discuss another person's journey, application status, eligibility, compensation, medical information, or personal circumstances.
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Request or share sensitive medical, legal, financial, personal information, Protected Health Information (PHI) (as outlined in the Program Agreement) from a prospective referral on Circle's behalf.
Confidentiality obligations continue after participation in the Program ends.
Section 5. Referral Standards
Advocates must use only their assigned Circle-approved referral link when sharing referral opportunities. Potential referrals must voluntarily submit their own information directly through the Advocate's referral link. Advocates may not submit referral information on behalf of another person.
Advocates may not pressure, manipulate, mislead, or coerce individuals into exploring surrogacy or engaging with Circle.
Referral ownership and attribution are determined solely by Circle's official records, systems, and current Program rules. A personal relationship with a prospective surrogate, intended parent, or other individual does not guarantee referral credit.
Section 6. FTC Disclosure Requirements
Advocates must comply with applicable endorsement and disclosure requirements and the current Circle Social Media and FTC Disclosure Guidelines.
When discussing Circle, sharing testimonials, promoting Circle-related content, or discussing rewards or referral opportunities, Advocates must clearly disclose their relationship with Circle whenever required.
Advocates must:
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Share only honest opinions and actual experiences.
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Avoid misleading, deceptive, or unsubstantiated claims.
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Use approved disclosure language when required.
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Make disclosures easy to notice and understand and appropriate for the format used.
Section 7. Content and Community Resources
Content, testimonials, photos, videos, stories, social media posts, educational materials, and other materials voluntarily submitted by Advocates may be used in accordance with the Circle Advocates Program Agreement.
Advocates understand and agree that submitted content may be used or shared by Circle, Circle's affiliated or related companies, authorized third-party vendors, service providers, marketing partners, community partners, and other Program participants for educational, awareness-building, advocacy, training, community engagement, promotional, marketing, recruiting, and other Program-related purposes.
Submitted content may appear in the Circle Advocates Portal, community resources, training materials, educational content, advocate resources, websites, social media channels, presentations, publications, marketing materials, and other Program-related materials.
Because submitted content may be distributed to others or incorporated into Program resources and assets, Advocates may not require Circle, its affiliated or related companies, authorized third parties, or other Program participants to recall, remove, modify, discontinue, or cease using content that was already published, distributed, shared, incorporated, produced, or committed to use before Circle received a written request concerning new uses.
Section 8. Conflicts of Interest
Advocates must promptly disclose any employment, contractor, ambassador, advocate, influencer, referral, consulting, ownership, financial, or representative relationship with another surrogacy agency, egg donation agency, fertility organization, or competing family-building service while participating in the Program.
Circle reserves the right to determine whether a conflict of interest exists and may restrict, suspend, or terminate participation when a conflict may interfere with the integrity of the Program, Circle's relationships, or the Advocate's responsibilities.
Section 9. Non-Circumvention
Advocates may not bypass, redirect, solicit, recruit, transfer, or steer prospective surrogates, intended parents, applicants, referrals, clients, or Program participants away from Circle for personal financial gain or on behalf of another person or organization.
Section 10. Program Violations and Corrective Action
Depending on the circumstances, a violation may result in education, content correction or removal, a warning, restricted Program benefits or portal access, suspension, permanent removal from the Program, or legal liability. Circle may take immediate action when reasonably necessary to address legal, compliance, privacy, safety, confidentiality, fraud, or reputational concerns.
Conduct that may result in immediate suspension or permanent removal includes:
- A breach of confidentiality or privacy.
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Fraudulent, manipulated, duplicate, deceptive, or misleading referrals.
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Misrepresentation of Circle, its services, Program opportunities, rewards, or the Advocate role.
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Harassment, discrimination, bullying, threats, or abusive conduct.
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Failure to make required disclosures or repeated noncompliance with Circle disclosure guidelines.
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False, misleading, or unsubstantiated claims about surrogacy, compensation, eligibility, outcomes, or Circle services.
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Unauthorized use or disclosure of confidential or personal information.
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Unauthorized media engagement or claiming authority to speak on behalf of Circle.
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Failure to disclose a material conflict of interest.
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Circumventing Circle or steering prospective referrals or participants to another organization for personal benefit.
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Conduct that creates a material legal, compliance, privacy, safety, fraud, or reputational concern for Circle or the community.
Section 11. Reporting Concerns
If an Advocate becomes aware of behavior that may violate this Code of Conduct, the concern should be reported promptly to the Circle Advocates Team through the current Program contact method.
Reports will be reviewed appropriately and handled as confidentially as circumstances permit. Retaliation against an individual who reports a concern in good faith is prohibited.
Section 12. Electronic Acceptance and Acknowledgment
Participation in the Circle Advocates Program is conditioned upon compliance with this Code of Conduct, the Circle Advocates Program Agreement, social media and FTC Disclosure Guidelines, current Rewards and Qualification Materials, and applicable Program Policies.
By checking the acceptance box and electronically accepting the Circle Advocates Program Agreement, the Advocate:
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Acknowledges that they have received or can access, read, and understand this Code of Conduct;
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Agrees to comply with this Code of Conduct and applicable Program Policies;
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Understands that electronic acceptance of the Circle Advocates Program Agreement also constitutes acceptance of this Code of Conduct, without a separate signature or checkbox;
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Understands that compliance with this Code of Conduct is a condition of continued participation in the Program;
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Understands that referral ownership and attribution are determined by Circle's official records, systems, and Program rules;
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Understands that Advocate-submitted content may be used and shared as described in the Circle Advocates Program Agreement and this Code of Conduct; and
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Understands that violations may result in corrective action, suspension, restriction of Program benefits or portal access, or removal from the Program.
Social Media & FTC Disclosure Guidelines
Purpose
As a Circle Advocate, you help educate and inspire others by sharing your authentic experiences and knowledge about surrogacy and family building. These Guidelines are designed to help you communicate responsibly, comply with applicable advertising and endorsement requirements, and maintain trust with your audience.
These Guidelines apply whenever you post, share, comment, create content, participate in online discussions, appear in videos, host events, or otherwise communicate publicly about Circle or the Circle Advocates Program.
1. Be Honest and Authentic
Always share truthful information and communicate from your own experience.
Do
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Share your genuine opinions and experiences.
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Speak honestly about your personal journey.
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Clarify when you are sharing personal experiences rather than general information.
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Refer medical, legal, financial, or program-specific questions to Circle.
Do Not
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Make false, misleading, or exaggerated statements.
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Promise outcomes, timelines, matches, compensation amounts, or results.
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Claim your experience is typical or guaranteed for others.
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Represent personal opinions as official Circle policies.
2. FTC Disclosure Requirements
Because you may receive rewards, incentives, compensation, or other benefits through the Circle Advocates Program, you may have a material connection to Circle. Whenever that relationship could influence how someone views your recommendation, clearly disclose your Circle Advocate relationship.
Clear Disclosure Examples
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I'm a Circle Advocate.
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I'm a Circle Advocate and may receive referral rewards.
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I partner with Circle as a Circle Advocate.
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As a Circle Advocate, I may receive rewards when someone qualifies through my referral link.
3. Where Disclosures Must Appear
Social Media Posts
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Place the disclosure near the beginning of the post when practical.
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Place it before the referral link.
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Include it in the main caption, not buried among hashtags.
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Use built-in platform disclosure tools where available.
Videos
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State the disclosure verbally when appropriate.
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Include it in the video description.
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Display it on screen when reasonable.
Stories and Reels
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Place the disclosure directly on screen.
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Use readable text that is easy to notice.
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Keep it visible long enough for viewers to understand it.
Live Streams
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Disclose the relationship at the beginning.
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Repeat the disclosure periodically during longer live events.
4. Referral Links
Advocates may receive referral credit only through their unique Circle-approved referral link. Prospective referrals must submit their own information directly through that link.
Do
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Share only your assigned referral link.
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Invite interested individuals to learn more through the link.
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Allow each person to decide independently whether to proceed.
Do Not
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Collect or submit another person's application yourself.
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Enter another person's information on their behalf.
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Create unofficial referral forms.
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Attempt to bypass the referral process.
5. Appropriate Content Topics
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Your own surrogacy experience.
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Why you chose Circle.
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The support you received during your journey.
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Family-building education.
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General information about surrogacy.
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Your personal motivations and experiences.
6. Claims You Should Avoid
Do not make statements that could be understood as promises or guarantees.
Avoid statements such as
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You'll definitely be matched quickly.
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Circle pays more than everyone else.
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Everyone has the same experience I had.
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This is the best agency.
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You'll earn a specific amount.
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Most women earn enough to pay off debt.
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You will qualify.
Use language such as
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Every journey is different.
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Circle can help determine whether you qualify.
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Compensation varies based on individual circumstances.
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This was my personal experience.
7. Respectful Communication
Do
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Be respectful and professional.
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Focus on your own experience.
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Share accurate information.
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Respond thoughtfully and constructively.
Do Not
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Harass, intimidate, bully, threaten, or attack others.
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Engage in public arguments on behalf of Circle.
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Post offensive, abusive, discriminatory, deceptive, or intentionally false content.
8. Discussing Other Agencies
Focus on sharing your own experience with Circle rather than criticizing or attacking another agency or organization.
Do
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Explain why you personally chose Circle.
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Discuss your experience honestly and accurately.
Do Not
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Make negative, defamatory, or disparaging statements about another agency.
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Compare agencies using unverified, inaccurate, or misleading information.
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Attack another agency's employees, surrogates, clients, or representatives.
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Engage in public disputes with another organization.
9. Privacy and Confidentiality
Never share confidential or private information. Do not disclose:
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Intended parent identities or private details.
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Surrogate personal information.
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Medical records or Protected Health Information (PHI).
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Private communications or screenshots.
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Non-public Circle business information.
Obtain any required permission before sharing stories, images, screenshots, or testimonials involving another person.
10. Media Inquiries
If a reporter, blogger, podcaster, or media outlet requests information about Circle, direct the inquiry to the Circle Advocates Team. Advocates may not present themselves as authorized Circle spokespersons.
11. Correcting Content
Circle may request modification, clarification, an additional disclosure, or removal of content that raises legal, compliance, privacy, accuracy, or brand concerns. Advocates are expected to cooperate promptly with reasonable requests.
12. Questions
If you are unsure whether a post, comment, disclosure, video, referral activity, or other communication follows these Guidelines, contact the Circle Advocates Team before posting.
Acknowledgment
Participation in the Circle Advocates Program requires compliance with the Circle Advocates Program Agreement, Circle Advocates Code of Conduct, these Social Media & FTC Disclosure Guidelines, current Rewards and Qualification Materials, and other applicable Program Policies.
Failure to follow these Guidelines may result in corrective action, suspension, removal from the Program, disqualification from rewards, or termination of participation as permitted under the Program Agreement and applicable policies.