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© 2019 Circulor 

Data Processing Privacy Policy

1. INTRODUCTION

This Circulor Data Processing Privacy Policy (also referred to as the ‘Privacy Policy’) informs consumers (‘you’) on the collection, use and sharing (collectively referred to as ‘processing’) of your personal information in connection with Circulor’s provision of data cloud services designed to help Circulor’s customers’ and partners’ online and offline activities (‘Circulor Data Clouds’). This Privacy Policy also explains the choices you have in relation to these processing activities.

This Privacy Policy was last updated on February 25, 2019. However, the Privacy Policy can change over time, for example to comply with legal requirements or to meet changing business needs. The most up-to-date version can be found on this website. In case there is an important change that we want to highlight to you, we will also inform you in another appropriate way (for example, via a pop-up notice or statement of changes on our website).

  • Circulor processes and uses personal data insofar as this is required for the performance of the contractual relationship with the customer.

  • Circulor shall only use personal data above and beyond the requirements for the fulfilment of the contract if permitted to do so by law or if you have provided us with your consent to do so.

  • Circulor may transfer customers' personal data to administrative and prosecuting authorities insofar as this is permitted by law.

As used in this Privacy Policy, ‘personal information’ or ‘personal data’ means information that relates to an identified individual or to an identifiable individual. For example, this could include among other things your name, address, email address, past purchase behavior or information regarding your online interests. Personal information about you that Circulor may process is also referred to as ‘information about you.’ For more detail about the types of information about you that we may process in the Circulor Data Cloud, please refer to Section 4 below.

2. SCOPE

The Privacy Policy applies to Circulor’s processing of information about you provided to the Circulor Data Cloud by our third party data suppliers to help enable Circulor Data Cloud customers and partners to market products and services to you based on your interests.

The Privacy Policy does not apply to the following activities:

  • First-party information collected about you by Circulor customers. Our customers are responsible for their own personal information collection practices or their use of their personal information for marketing and other purposes, including when they use the Circulor Data Cloud to send you online advertising. To find out more about our customers’ use of first-party information about you, you are encouraged to review the relevant privacy policy of the company who collected your information from you or is sending you advertising. Please consult that company if you have any further questions about its use of information about you.

  • Data collected for Circulor’s own direct marketing purposes. For information about Circulor’s processing activities with regard to your personal information collected on Circulor websites and applications and used for Circulor’s own direct marketing purposes, please refer to Circulor's General Privacy Policy.

3. WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL INFORMATION?

Circulor Corporation and its affiliated entities are responsible for processing your personal information in scope of this Privacy Policy. Please refer to Section 18 for contact details and the registered addresses of Circulor Corporation. A list of Circulor entities is available upon request.

4. WHICH TYPES OF PERSONAL INFORMATION DO WE PROCESS AND FROM WHICH SOURCES?

Circulor may process both offline and online information about you, including information from publicly available sources or third party data providers.

  • Offline information about you is obtained by Circulor from its offline partners such as brick-and-mortar retail stores, grocery stores and their associated loyalty card programs, payment card brands, catalog orders and consumer survey programs, and third parties who may not have a relationship with you and collect offline information from their offline partners.

  • Online information about you originates from your activities on sites operated by our online partners, such as advertising agencies and website operators (for example, online retail stores or travel sites). Circulor also obtains online information from third parties who may not have a relationship with you and who collect online information using cookies or similar technologies, such as pixels tags and device identifiers, as you browse the Internet and interact with websites. For more information on cookies and similar technologies used in connection with Circulor Data Cloud, please refer to Section 11 below.

Information about you may in some cases directly identify you, while in other cases it may only indirectly identify you. Personal information that is collected offline and that can directly identify you may include, for example:

  • name and physical address, email addresses, and telephone numbers;

  • demographic attributes, when tied to other information that identifies you;

  • transactional data based on your purchases, when tied to other information that identifies you;

  • company data such as the name, size and location of the company you work for and your role within the company;

  • data from marketing opt-in lists, consumer surveys, or publicly available information;

  • For the United States only: derived latitude/longitude from a physical address.

Personal information that is collected online and that may indirectly identify you may include, for example:

  • unique IDs such as your mobile device identifier or a cookie ID on your browser;

  • IP addresses and information derived from IP addresses, such as geographic location;

  • information about your device, such as browser, device type, operating system, the presence or use of “apps”, screen resolution, or the preferred language;

  • obfuscated personal information such as hashed email addresses (direct identifiers are removed);

  • demographic information such as gender, age, and income range when not tied to information that directly identifies you;

  • behavioural data of the internet connected computer or device you use when interacting with websites, applications, or other connected devices, such as advertisements clicked or viewed, websites and content areas, date and time of these activities, or the web search used to locate and navigate to a website.

We may associate personal information about you with interest segments or profiles as part of the provision of Circulor Data Cloud services to our customers and partners:

  • Interest segments are a specific group of consumers that share a common behaviour or preference used for direct marketing by our customers. For example: in market for travel specials to Hawaii.

  • Profiles are a set of attributes about a specific consumer or device, or a set of multiple consumers or devices sharing common attributes used for marketing by our customers. For example: age bracket 25-55; adventurous traveller; surfing enthusiast; in market for travel specials to Hawaii.

5. WHY AND HOW DO WE USE YOUR PERSONAL INFORMATION?

We use personal information for the following purposes:

  • a) to help enable Circulor Data Cloud customers and partners to market products and services to you based on your interests;

  • b) for personal information collected outside the EU/EEA, to analyze, develop, improve, and optimize the use, function and performance of Circulor products and services;

  • c) to manage the security of our sites, networks and systems;

  • d) to comply with applicable laws and regulations and to operate our business.

These purposes are described below in further detail.

  • a) To help enable Circulor Data Cloud customers and partners to market products and services to you based on your interests

We process personal information about you to help enable Circulor Data Cloud customers and partners to market products and services to you via online and offline marketing activities based on your interests.

More specifically, Circulor can process information about you:

  • i. For online interest-based advertising delivered through Circulor Data Cloud partners that display online advertising to you on behalf of Circulor Data Cloud customers.
     

  • ii. For offline and online campaign measurement, analytics, and development of insights on behalf of our Circulor Data Cloud customers.
     

  • iii. For enabling our Circulor Data Cloud customers to personalize their products and services, including site optimization, email personalization and dynamic marketing and advertising optimization.
     

  • iv. For linking Profiles and Interest Segments to enable Circulor Data Cloud customers and partners to connect your Interest Segments across the various browsers and/or devices you may use for the purposes described in this section. 
     

  • v. For creating modelled online and offline audiences for Circulor Data Cloud customers’ products and services.
     

  • vi. For enabling our Circulor Data Cloud customers to associate first-party information to certain Circulor Data Cloud identifiers in order to deliver marketing and advertising services to you.
     

  • vii. For the United States only: to allow our customers to deliver catalogues to your physical address that may be of interest to you based on your previous purchase behavior.


 

  • b) For personal information collected outside the EU/EEA, to analyze, develop, improve, and optimize the use, function and performance of Circulor products and services 

    We may process personal information for Circulor’s own research and development purposes.

    For example: to enhance data quality, develop new features and functionality, and for statistical analyses related to the performance and operation of the Circulor Data Clouds. 

     

  • c) to manage the security of our sites, networks and systems

    We can collect usage and systems operations data from the Circulor Data Cloud for security and operations management to help keep our networks and systems as well as our products and services secure, or to investigate and prevent cyber-attacks or potential fraud, including ad fraud and to detect bots.

     

  • d) to comply with applicable laws and regulations and to operate our business

    Circulor may transfer customers' personal data to administrative and prosecuting authorities insofar as this is permitted by law. In some cases, we may process personal information to comply with applicable laws and regulations. For example, to respond to a request from a regulator or to defend a legal claim. We may also process personal information in the operation of our business. For example, to conduct audits and investigations, for finance and accounting, archiving and insurance purposes.


 

6. FOR INFORMATION ABOUT YOU COLLECTED IN THE EU/EEA, WHAT IS OUR LEGAL BASIS?

We rely on your consent for the purpose of enabling Circulor Data Cloud customers and partners to market products and services to you, including measurement and analytics on campaign performance, personalization, modelling, onboarding, and linkage (see Section 5 above for additional details on these purposes). Your consent is obtained on behalf of Circulor and its Circulor Data Cloud customers and partners by our third party data providers.

You have the right to withdraw your consent to this purpose at any time. Please refer to Section 12 below for more details on how to opt out of interest-based data processing based on your consent.

In addition, we may process some information about you as may be necessary based on our legitimate interest to maintain the security of our sites, networks, and systems, and to comply with applicable laws and regulations, such as to process an opt-out request.

7. FOR WHAT PERIOD DO WE RETAIN INFORMATION ABOUT YOU?

Circulor maintains information about you for the following retention periods:

  • a) Online information about you is retained for up to 13 months.

    Exceptionally and for online information collected outside the EU/EEA, online information may be retained up to 18 months, for example for Circulor customers’ seasonal or cyclical interest-based advertising campaigns or internal analytics and model development.

     

  • b) Online information about you for linkage purposes (cross device/cross-context technology) is retained for up to 12 months.
     

  • c) Offline information about you may be retained for up to 5 years if it was collected in the EU/EEA. We retain offline information about you in other regions as relevant for applicable purposes in those regions (also see Section 5 above). 
     

  • d) Personal information necessary to preserve opt-out preferences is retained for 20 years, unless you delete it or otherwise prevent its collection as further described in Section 12 below.

8. WHEN AND HOW CAN WE SHARE YOUR PERSONAL INFORMATION?

Sharing within Circulor

As a global organization, information about you can be shared globally throughout Circulor's worldwide organization. A list of Circulor entities is available here. Please select a region and country to view the registered address and contact details of the Circulor entity or entities located in each country.

Circulor employees are authorised to access personal information only to the extent necessary to serve the applicable purpose(s) and to perform their job functions.

Sharing with third parties

We may share personal information with the following third parties:

  • Circulor Data Cloud customers and partners, including digital marketers, ad agencies, web publishers, demand side platforms, data management platforms, supply-side platforms and social media networks;

  • third-party service providers as necessary to perform Circulor Data Cloud services on behalf of Circulor;

  • relevant third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock, including in connection with any bankruptcy or similar proceedings;

  • public and government authorities, including public and government authorities outside your country of residence (to the extent legally required to respond to their mandatory requests in connection with national security and/or law enforcement purposes).

When third parties are given access to personal information, we will take appropriate contractual, technical and organizational measures designed to ensure that personal information is processed only to the extent that such processing is necessary, consistent with this Privacy Policy and in accordance with applicable law.

9. HOW IS PERSONAL INFORMATION HANDLED GLOBALLY?

Circulor is a global corporation and personal information is processed globally. If personal information is transferred to an Circulor recipient in a country that does not provide an adequate level of protection for personal information, Circulor will take measures designed to adequately protect information about you, such as ensuring that such transfers are subject to the terms of the EU Model Clauses.

Circulor also complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention when a customer.

10. HOW IS INFORMATION ABOUT YOU SECURED?

Circulor has implemented appropriate technical, physical and organizational measures designed to protect personal information against accidental or unlawful destruction or accidental loss, damage, alteration, unauthourised disclosure or access, as well as all other forms of unlawful processing.

11. WHAT COOKIES, PIXEL TAGS AND OTHER SIMILAR TECHNOLOGIES DO WE USE?

Cookies and similar technologies (e.g., pixels tags and device identifiers) are used by Circulor and our advertising technology partners to recognize you and/or your device(s) on, off and across different services and devices for the purposes specified in Section 5 above.

Cookies are small text files that contain a string of characters and uniquely identify a browser on a connected device. We or our Circulor Data Cloud partners may use cookies to, among other things, track user trends and collect information about how you use our customers’ sites or interact with advertising. Most browsers are initially configured to accept cookies by default. You may, however, be able to change your browser settings to cause your browser to refuse third-party cookies or to indicate when a third-party cookie is being sent. Check your browser’s “help” files to learn more about handling cookies.

Pixel Tags (also called web beacons or clear GIFs) are invisible 1 x 1 pixels that are placed on webpages that use this technology for marketing and measurement purposes. When you access these webpages, pixel tags generate a generic notice of the visit. Pixel tags can be used with cookies or alone. When used with cookies, pixel tags can track activity on a site by a particular device and provide relevant online advertising to you. When you turn off cookies or have opted out of cookies, pixel tags simply detect a unique website visit and how you interacted with the advertising but do not track an individual to provide relevant online advertising.

You can opt out of cookies using the opt-out tools in the next section.

12. WHAT ARE YOUR CHOICES?

We provide multiple choices in respect to the information we process about you. You can exercise these choices as described below.

Opt-out and object to our use of information about you

Circulor offers multiple ways for you to opt out and object to our use of information about you:

  • Circulor Data Cloud Opt out. You can access the Circulor Data Cloud opt-out tool here.

    Please note that if you use this opt-out tool, Circulor will opt you out of Circulor’s use of information about you for Circulor Data Cloud services involving both first-party use of your information as well as any third-party use of your information. See Section 2 above for more information on the distinction between first party and third party information.

  • AdTech Industry Opt Out. You may also opt out of our processing of information about you for Circulor Data Cloud services by using the opt-out tools provided by the following industry groups:

  • Mobile Opt Out. While the opt out methods described above often also work for mobile web browsing, mobile ‘app’ environments do not accept cookies. You may want to consider installing the AppChoices App provided by the Digital Advertising Alliance (DAA) to exercise opt-out control for specific companies, including Circulor, when in a mobile app environment. More information on how to download and configure the AppChoices App relevant for your mobile platform is available here.

  • Do Not Track. Circulor honors “Do Not Track” browser settings, meaning we will not track your browser for marketing purposes while you have “Do Not Track” turned on in your browser settings.

Please note that if you opt out using any of the first three opt out tools, you may still temporarily see interest-based advertising from Circulor Data Cloud customers due to advertising campaigns from those customers already underway. However, you will be opted-out of all future advertising campaigns from customers that use the Circulor Data Cloud.

Also note that the first three opt out tools are currently cookie-based and prevent Circulor from using your personal information for interest-based advertising on the browser on which they are installed. As a result, these opt out tools will only function if your browser is set to accept third-party cookies and may not function where cookies are sometimes automatically disabled or removed (e.g., certain mobile devices and operating systems). If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you will need to opt out again. Circulor does not use persistent, unique identifiers to revive a previously opted-out profile or deleted cookie.

If you want to opt you out of Circulor’s use of information about you for Circulor Data Cloud services, but do not want to receive third-party cookies, you can also change your browser settings on your computer or other device you are using to connect to the internet. Most browsers also provide functionality that lets you opt out of all advertising cookies, including Circulor cookies.

Delete information about you

If you would like to submit a request to have online and/or offline information about you, if any, erased or deleted, you can use this form.

Access information about you

In order to exercise your right to access your online information stored in the Circulor Data Cloud, you can use the Circulor Data Cloud Registry (‘Registry’) to view the online segments Circulor has associated with your device. By accessing this Registry, you can view the types of third-party interest segments that are available for Circulor Data Cloud customers. Please note that the interest segments you see within the Registry is information from the profile associated with the specific browser, computer or device that you are using to visit the Registry. You may see different segments when viewing the Registry from a different browser, computer or device. For a complete picture of the segments associated with all of your browsers and devices, we therefore recommend using these different browsers and devices when accessing the Registry.

For a copy of your offline information, please contact the Circulor Global Data Protection Officer as set out in Section 16 below. While the majority of offline access requests can be handled quickly, complex requests may take more research and time. In such cases, you will be contacted regarding the nature of the request and appropriate next steps within one month from the date of receipt of your request. We cannot provide offline first-party information that is collected and maintained by our customers. If you have questions in regards to first-party information, Circulor recommends that you contact directly the company that collected it from you.

13. DOES THE CIRCULOR DATA CLOUD COLLECT SENSITIVE PERSONAL INFORMATION?

Circulor does not create any online interest segments that reflect personal information that we consider sensitive. While the types of personal information considered sensitive may vary among consumers and applicable law, we treat the following types of personal information as sensitive:

  • precise health information, such as a consumer having a certain medical condition like cancer or diabetes;

  • certain aspects of a consumer’s personal life or financial situation;

  • information considered sensitive based on applicable law, such as special categories of data if you are in the EU/EEA.

We do not allow Circulor Data Cloud customers or partners to use the Circulor Data Cloud services for employment, credit, healthcare, or insurance eligibility purposes.

14. DOES THE CIRCULOR DATA CLOUD COLLECT PERSONAL INFORMATION FROM CHILDREN?

We do not intentionally collect personal information from, and do not tailor any services to, children under 16 years of age. Further, we prohibit our Circulor Data Cloud partners from providing Circulor with personal information from sites directed to children under the age of 16 or from consumers whose age these companies know to be under the age of 16.

15. IS CIRCULOR A MEMBER OF ANY INDUSTRY ORGANISATIONS?

Circulor is a member of, and adheres to, the self-regulatory principles of the following industry organisations:

  • The Linux Foundation; and

  • Hyperledger.

As a member of these organizations, Circulor works with industry-leading companies to address important privacy and consumer protection issues.

16. HOW TO CONTACT CIRCULOR IF YOU HAVE QUESTIONS, COMMENTS OR COMPLAINTS?

Circulor has appointed a Global Data Protection Officer. If you believe your personal information has been used in a way that is not consistent with the Privacy Policy or your choices, or if you have further questions, comments or suggestions related to this Privacy Policy, or if you wish to exercise your right to access to your offline personal information as described in Section 12 above, please contact the Global Data Protection Officer by filling out an inquiry form.

Written inquiries to the Data Protection Officer may be addressed to:

Circulor Ltd
Global Data Protection Officer
96 Kensington High Street

London

W8 4SG

UK

17. DISPUTE RESOLUTION OR FILING A COMPLAINT

If you have any complaints regarding our compliance with this Privacy Policy, please contact us first. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with this Privacy Policy and in accordance with applicable law.

You also have the right to file a complaint with a competent data protection authority if you are a resident of a European Union member state.

18. CIRCULOR CORPORATE HEADQUARTERS

Circulor's corporate headquarters are located at:

96 Kensington High Street

London

W8 4SG

Tel: +44 (0)203 858 0555