attendees of Circulor events;
customers and prospective customers and their representatives;
subscribers to Circulor newsletters;
suppliers and business partners and their representatives.
When interacting with our websites, you also have the ability to link or connect with non-Circulor websites, services, social networks, applications or other features. Enabling these features will lead to other parties than Circulor processing information about you. Circulor does not have any control over these features of other parties. We encourage you to review the privacy policies of these parties before using these features.
3. WHO IS RESPONSIBLE FOR YOUR PERSONAL INFORMATION?
4. WHICH TYPES OF PERSONAL INFORMATION DO WE PROCESS AND FROM WHICH SOURCES?
Circulor can process information about you collected both offline and online.
Offline information about you originates from our interactions with you during in-person meetings or at Circulor events, conferences, workshops or gatherings;
Online information about you originates from your activities on our sites, for example, in relation with your Circulor accounts, (pre-)sales inquiries or subscription to our newsletters, or from your interactions with Circulor via electronic communication tools such as email or telephone. Information about you may also be provided by third party sources, such as data aggregators who may not have a relationship with you.
Information about you that Circulor may be collect and process includes:
name and physical address, email addresses, and telephone numbers;
demographic attributes, when tied to personal information that identifies you;
photographs and testimonials;
transactional data, including products and services ordered, financial details and payment methods;
company data such as the name, size and location of the company you work for and your role within the company;
data from surveys and publicly available information, such as social media posts;
unique IDs such as your mobile device identifier or cookie ID on your browser;
IP address and information that may be derived from IP address, such as geographic location;
information about a device you use, such as browser, device type, operating system, the presence or use of "apps", screen resolution, and the preferred language;
behavioral data of the internet connected computer or device you use when interacting with the sites, such as advertisements clicked or viewed, sites and content areas, date and time of activities or the web search used to locate and navigate to a site.
Please note that Circulor does not control the content that you may post to Circulor forums or social networks; in some cases, such content may be publicly available on the Internet. You should carefully consider whether you wish to submit personal information to these forums or social networks and whether you wish to make your profile available to other users, and you should tailor any content you may submit accordingly.
5. WHY AND HOW DO WE USE YOUR PERSONAL INFORMATION?
We may use personal information for the following purposes:
to communicate and respond to your requests and inquiries to Circulor;
to deliver functionality on our sites and for their technical and functional management;
to administer subscriptions of Circulor newsletters;
to market our products and services or related products and services, and to tailor our marketing and sales activities to your or your company’s interests;
to engage in transactions with customers, suppliers and business partners and to process orders for Circulor products and services;
to analyse, develop, improve and optimize the use, function and performance of our sites and products and services;
to manage the security of our sites, networks and systems;
to comply with applicable laws and regulations and to operate our business;
These purposes are described below in further detail.
To communicate and respond to your requests and inquiries to Circulor
If you get in touch with us (such as by submitting contact forms on our sites, attending Circulor events or other occasions, sending an email or by visiting social media platforms), we process information about you to communicate with you and to respond to your requests or other inquiries. We can also process personal information to interact with you on third party social networks.
To deliver functionality on our sites and for their technical and functional management
When you choose to register with us (such as to make use of our communities), we need to process the personal information provided by you so that we can create and manage a personal account for you. Upon creating your account, we will send you your personal login information. This personal information enables us to administer your account, for example by changing your password for you.
To administer subscriptions of Circulor newsletters
If you subscribe to our newsletters, we process information about you to administer your subscription to our magazines (including the renewal process).
To market our products and services or related products and services and to tailor marketing and sales activities
Circulor may use information about you to notify you about new product releases and service developments, events, alerts, updates, prices, terms, special offers and associated campaigns and promotions (including via newsletters). Circulor may also use personal information to advertise Circulor's products and services or related products and services, and also to have our distributors, resellers or partners notify you about our products or services or their related products or services (such as via joint sales or product promotions). We do our best to tailor your website visit, marketing experience and our communications to your expressed interests. This happens, for example, if you sign up for a Circulor community or program.
If you attend an event, Circulor may process information about you gathered in relation to the event and can share information about your attendance with your company. Circulor may also permit designated event partners or conference sponsors to send you up to two communications related to your event attendance. Please note that our partners or conference sponsors may directly request information about you at their conference booths or presentations, and their use of your information that you provide to them will be subject to their privacy policies.
We may also process your personal information to post testimonials on our sites, but will first obtain your consent to use your name and testimonial.
To engage in transactions with customers, suppliers and business partners and to process purchases of our products and services
If you place an order for our products and services, or if you provide services to Circulor, our employees, customers or partners as a supplier or business partner, Circulor processes information about you to engage in and administer the relevant transactions (such as by sending invoices and making payments), administer your order, and help you get started and adopt our products and services (e.g., by contacting you to activate your Cloud services). If you download products or services from our sites, Circulor uses information about you to confirm certain information about your order (for example, that you did not experience problems in the download process).
To analyse, develop, improve and optimize the use, function and performance of our sites and products and services
We may process personal information in order to analyse, develop, improve and optimize the use, function and performance of our sites and products and services, as well as marketing and sales campaigns. In case the sites permit you to participate in interactive discussions, create a profile, post comments, opportunities or other content, or communicate directly with another user or otherwise engage in networking activities, Circulor may process personal information when moderating these activities.
To manage the security of our sites, networks and systems
We may collect site use data for security and operations management to help keep our sites, networks and systems secure, or to investigate and prevent potential fraud, including ad fraud and cyber-attacks and to detect bots.
To comply with applicable laws and regulations and to operate our business
In some cases, we have to 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 performance and operation of our business, such as to conduct internal audits and investigations or for finance and accounting and archiving and insurance purposes.
6. WHAT IS OUR BASIS FOR PROCESSING INFORMATION ABOUT YOU?
For personal information collected about you in the EU, our basis for processing is the following:
In order to communicate adequately with you and to respond to your requests, we need to process information about you and therefore have a legitimate interest in processing this information.
In order to engage in transactions with customers, suppliers and business partners, and to process purchases and downloads of our products and services, we need to process information about you as necessary to enter into or perform a contract with you.
We process personal information for marketing and sales activities based on your consent where so indicated on our sites at the time your personal information was collected, or further to our legitimate interest to market and promote our products and services.
We rely on our legitimate interest to analyse, develop, improve and optimize our sites, products and services, and to maintain the security of our sites, networks and systems.
In order to comply with applicable laws and regulations, such as to comply with a subpoena or other legal process, or to process an opt-out request.
7. FOR WHAT PERIOD DO WE RETAIN PERSONAL INFORMATION
Circulor maintains personal information for the following retention periods:
Information about you we collect to engage in transactions with our customers, suppliers and business partners, and to process purchases of our products and services, will be retained for the duration of the transaction or services period, or longer as necessary for record retention and legal compliance purposes.
If you have registered for a Circulor account, your account information will be retained for as long as you maintain an active account. Your account and account information will be deleted if you do not log in for 18 consecutive months. Circulor retains records of that deletion for 90 days.
If you have registered for our newsletters and blogs, your subscription data will be retained for as long as you are subscribed to our distribution lists. Circulor retains records of that deletion for 30 days.
Contact information such as your email address or phone number collected online on our sites or offline from our interactions with you at Circulor events and conferences, and used for direct marketing and sales activities will be retained for as long as we have an active (customer) relationship with you. We treat you as an active contact if (i) you have interacted with Circulor or updated your contact details and preferences in the past 18 months; and (ii) you have not made a deletion request.
Personal information needed to retain your opt-out preferences is retained for 20 years (or longer as necessary to comply with applicable law).
8. WHEN AND HOW CAN WE SHARE YOUR PERSONAL INFORMATION?
Sharing within Circulor
As a global organisation, information about you may be shared globally throughout Circulor's worldwide organisation. A list of Circulor entities is available upon request.
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:
Third-party service providers (for example, credit card processing services, order fulfilment, analytics, event/campaign management, website management, information technology and related infrastructure provision, customer service, e-mail delivery, auditing, and other similar service providers) in order for those service providers to perform business functions on behalf of Circulor;
Circulor distributors or resellers for further follow-up related to your interests, specific partners that offer complementary products and services or with third parties to facilitate interest-based advertising;
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);
As required by law, such as to comply with a subpoena or other legal process, when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to government requests, including public and government authorities outside your country of residence, for national security and/or law enforcement purposes.
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 YOUR PERSONAL INFORMATION SECURED?
Circulor has implemented appropriate technical, physical and organisational measures designed to protect personal information against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorised disclosure or access, as well as all other forms of unlawful processing.
11. WHAT COOKIES AND SIMILAR TECHNOLOGIES DO WE USE ON OUR SITES?
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.
Which types of cookie are used by Circulor?
Please click here for more information on the types of cookies used by Circulor.
How can I manage my cookie preferences?
If you are a visitor or our sites, you can use our cookie preferences tool to opt out of cookies that are not required to enable core site functionality, such as advertising and functional cookies here.
12. WHAT ARE YOUR CHOICES?
We provide multiple choices in respect of the information we process about you:
Opt-out of our use of your personal information
You may withdraw consent you have previously provided for the processing of information about you, including for email marketing by Circulor.
Delete personal information
You can ask us to erase or delete all or some of the information about you.
Change or correct personal information
You can edit some of the information about you by. You can also ask us to change, update or fix information about you in certain cases, particularly if it is inaccurate.
Object to, or limit or restrict use of personal information
You can ask us to stop using all or some of the information about you (for example, if we have no legal right to keep using it) or to limit our use of it (for example, if the information about you is inaccurate).
Right to access and/or have your information provided to you
You can also ask us for a copy of information about you and can ask for a copy of information about you provided in machine readable form if you reside in the EU or other country that provides you this right as a matter of law.
You can exercise these choices in accordance with applicable laws by filling out our inquiry form.
13. DO YOU COLLECT SENSITIVE INFORMATION AND INFORMATION FROM CHILDREN?
Sensitive personal information
We ask that you do not send us, and do not share any sensitive personal information (for example, government-issued IDs, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, genetic, or biometric data, criminal background or trade union membership).
As a company focused on serving the needs of businesses, Circulor's sites are not directed to minors and Circulor does not promote or market its services to minors, except in very limited circumstances as part of specific educational outreach programs with parental permission. If you believe that we have mistakenly or unintentionally collected personal information of a minor through our sites without appropriate consent, please notify us through our inquiry form so that we may immediately delete the information from our servers and make any other necessary corrections. Additionally, please use this same form to request removal of content or information that was posted to our sites when the registered user was under the age of 16. Please note that such requests may not ensure complete or comprehensive removal of the content or information, as, for example, some of the content may have been re-posted by another user.
14. DATA PROTECTION OFFICER
Written inquiries to the Data Protection Officer may be addressed to:
Global Data Protection Officer
96 Kensington High Street
15. DISPUTE RESOLUTION OR FILING A COMPLAINT
16. CIRCULOR CORPORATE HEADQUARTERS
Circulor's corporate headquarters are located at:
96 Kensington High Street
Tel: +44 (0)203 858 0555