Circulor Data Processing Policy 

The Circulor group of companies (the “Company”) processes certain data relating to its customers and their businesses when providing services to those customers (each a “Client”).

Where the Client has entered into a customer services agreement with the Company (a “CSA”), the terms of this data processing policy shall be hereby incorporated into such CSA.

The Company may update this policy from time to time, and the latest version of this policy shall always be deemed to be incorporated into each Client’s CSA.

This policy was last updated in September 2020.


Raw Data

For the purposes of this policy, “Raw Data” shall include all commercially sensitive data provided by the Client to the Company as part of the Services. The Raw Data shall not include any personal data. When the Company provides the Services to the Client under the CSA, the Client shall provide the Company with the Raw Data.

The Raw Data shall be utilised by the Company to derive insights and intelligence, alongside the raw data of others (the “Output Data”).

The Output Data shall be stored in an immutable record on the Company’s blockchain system and shall be provided to the Company’s customers, including companies within the same industry and supply chain as the Client. At no time will the Company provide the Raw Data to any third party, including any client of the Company, and the Company shall maintain the confidentiality of the Raw Data during the Term and perpetually thereafter.

In the event of termination of the CSA, the Company shall continue to be able to store, use and sell the Output Data. The Client acknowledges and agrees that termination of the CSA shall not require the Company to delete or destroy any Output Data.

Proprietary Rights

The Raw Data and all intellectual property rights subsisting therein shall remain the property of the Client (or its licensors, as appropriate) and the disclosure of the Raw Data to the Company shall not confer upon the Company any rights whatsoever in any part of the Raw Data.

The Output Data and all intellectual property rights subsisting therein shall be the sole and exclusive property of the Company, to deal with as it sees fit (including for commercial purposes). Nothing in this policy shall provide the Client with any intellectual property rights in the Output Data.

Law and Jurisdiction

This policy (including any non-contractual matters and obligations arising therefrom or associated therewith) shall be governed by, and construed in accordance with, the laws of England and Wales.

Any dispute, controversy, proceedings or claim between the Parties relating to this policy (including any non- contractual matters and obligations arising therefrom or associated therewith) shall fall within the jurisdiction of the courts of England and Wales.