Last updated June 2020
Your privacy is important to Circulor. This policy sets out information on the personal data we collect about you, and your rights in respect of this data. This policy applies whether you use our services, whether technical support, consulting services or any other services (the “Services”) or use our website (circulor.com) (the “Website”).
Our Website may contain links to third party websites that are not covered by policy. We therefore ask you to review the privacy statements of other websites and applications to understand their information practices.
If you have any comments on this policy, please email them to email@example.com
This policy contains the following information (you can access a specific section of this policy by clicking below):
Information about who we are
Information on what we can collect
Information on cookies
How we store your personal data
How we disclose your information
Your rights regarding your personal data
What happens when we link to other websites
The changes we may make to the policy
Who We Are
Our company name is Circulor. Our registered address is 142 Cromwell Road, London, United Kingdom, SW7 4EF. If you wish to speak to someone about the policy, please contact us at firstname.lastname@example.org
We respect your right to privacy and will only process personal information about you in accordance with applicable data protection laws. We comply with General Data Protection Regulation (2016/679) and the UK Data Protection Act 2018. If any of these laws are replaced or superseded, we will also comply with that.
What we may collect
Personal data, or personal information, is any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect data about you that is not personal, i.e. it is public information. This includes information that is taken from publicly available websites or social media sites. This is not personal data and is not held in accordance with this policy.
We may collect, use, store and transfer different kinds of personal data about you when you use our Website or use our Services. Whenever we collect personal data about you, we must have a legal ground to do so.
When you use our Website
When you use our Website for sales or pre-sales enquiries, or where you create an account with us, we will ask you to provide your email address and name. It is your decision whether to provide your full name.
We use this information to allow you to sign into an account on our Website. The legal basis for us collecting this information is legitimate interest – the information is required to protect your online account.
If you contact a member of our team to discuss customer service matters, we will use your name and email address when we interact with you. The legal basis we have for this is to provide you with assistance regarding customer service matters.
We will then use your name and email address to send you information about your account (including changes to this policy or security information) or to discuss our Services. Our legal basis for using your name and email address in this way is to provide you with relevant information relating to the security of your online account, and also to ensure you have up-to-date information on how we handle your personal data.
We may ask you whether you want to opt-in to our marketing information, including newsletters. If you say yes to this, we will use your email address to provide you with marketing information about our products and services. Our legal basis for this is that you have provided your consent. You can withdraw your consent at any time by contacting us at email@example.com
We may collect information when you access our Website, such as your IP address, the device type you have used, your preferred language and how you interact with our Website. We may use this information to determine how users interact with our Website, in order that we can improve our Website and our Services. Our legal basis for using this information is legitimate interest to improve your experience of our Website and Services provided to you.
When you attend a Circulor event
When you sign up attend one of our events, you will be asked to provide your name and email address (as set out above). This allows us to identify you when you attend the event. Our legal basis for this is legitimate interest, to ensure that only those who have signed up to attend an event participate in that event.
When you are our customer
When you purchase goods or Services from us, we will collect information such as your name, address, email address, telephone number and payment details. We require this information so that we can provide you with the goods or Services you have purchased. We may also use this information to keep your goods or Services updated, to comply with applicable law and regulation, to maintain security of networks and systems, to improve and develop our goods or Services, or to engage in further transactions with you. We will only collect the information necessary to provide you with those goods or Services. Our legal basis for using this information is to perform a contract with you.
If you buy from us and, as a result, we process personal data that you have given us, you are the data controller and we are the data processor. In such case, we will enter into a data processing agreement with you.
We will never collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). If this changes, we will update this policy, and ask for your consent to process this information.
We do not collect any personal information about anyone under the age of 16.
Information on cookies
Cookies are small text files placed on your device when you visit our site and are used to make the users experience more efficient. We are able to store cookies on your computer where they are necessary for the operation of the site however, for non-essential cookies we need your permission.
These are the types of cookies we use:
'Session cookies' allow us to track your actions during a single browsing session, but they do not remain on your device afterwards
'Persistent cookies' remain on your device between sessions. We use them to authenticate you and to remember your preferences. We can also use them to balance the load on our servers and improve your experience on our Website
Session and persistent cookies can be either first- or third-party cookies. A first-party cookie is set by the Website being visited; a third-party cookie is set by a different website. Both types of cookie may be used by us or our business partners.
The third-party cookies we use are:
Google Analytics – this is a web analytics service provided by Google, Inc. The cookies used by Google Analytics help us to analyse how users use our website and to count the number of people who use it. Google Analytics stores your IP address anonymously. Google does not associate your IP address with any personally identifiable information
Facebook Ads – these cookies collect information about how visitors use our website. This data is collected anonymously and is used to help improve our website’s functionality
Google Ad Words – these cookies collect information about how visitors use our website. This data is collected anonymously, to help make our marketing communications more relevant, and is used to improve our website’s functionality
All our cookies are categorised by the role they fulfil on our Website:
a. Strictly Necessary: these are essential to enable you to move around our Website and use features such as secure services. Without these cookies such services could not be provided;
b. Functionality: allow the website to remember your choices and to personal certain features. These cookies may be anonymised and cannot track your browsing activity on other websites; and
c. Performance: collect information as to how users use the Website. These cookies don't collect information that identifies a visitor. The information collected is aggregated and used to improve our Website.
d. None of the cookies employed are classified as Behavioural Targeting.
We will always ask for your consent to use non-essential cookies. You are free to withhold consent to this, but it means that we might not be able to provide the full Website experience to you, including some Services.
If at any time you wish to disable our cookies, you may do so through the settings on your browser, or whenever the pop-up appears on our Website (each time you access the Website).
How we store your personal data
We store all your personal data on our servers within the United Kingdom.
We may transfer your collected data to storage outside the European Economic Area (EEA). It may be processed outside the EEA to fulfil your order and to receive our services and deal with payment. If we do store or transfer data outside the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA.
This means that sometimes we may need to use legally binding contractual terms between us and any third parties we engage with and the use of the EU-approved Model Contractual Arrangements.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see the European Commission: EU-US Privacy Shield.
Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our Website. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know.
If there is an incident where we become aware that there has been a data breach, we will let you know without undue delay. We will then take all necessary steps, including informing the Information Commissioner’s Office in the UK, to limit the extent of the breach and to prevent a further reoccurrence.
We will still be responsible for protection of your personal data, even where we have transferred it outside the EEA.
We will keep your personal data for a maximum of 7 years after our relationship with you ends in order to comply with legal and regulatory requirements. We will delete your personal data sooner if possible.
If you have created an account on our Website, and you do not log in for 18 consecutive months, we will delete your personal data. We will retain records of that deletion for 90 days.
If you subscribe to a newsletter, we will keep your data for as long as you are subscribed. If you unsubscribe from a newsletter, we will retain records of that deletion for 30 days.
We regularly review our data retention obligations to ensure we are not retaining data for longer than we are legally obliged to.
How we disclose your information
We may disclose your information in the following cases:
If we want to sell our business, or our company, we can disclose it to the potential buyer
We can disclose it to other businesses in our group, as defined in the Companies Act 2006
We can disclose it if we have a legal obligation to do so, or in order to protect other people's property, safety or rights
We can exchange information with others to protect against fraud or credit risks
We may contract with third parties to supply services to you on our behalf. These include:
Credit card processing services
Order fulfilment service providers
Analytics service providers
Event/campaign management service providers
Website management service providers
Information technology and related infrastructure provision
Email delivery services
Our auditors and legal advisors
These third parties are known as sub-processors. Where we share your personal data with those sub-processors, they will be bound by confidentiality obligations. We do this to ensure your personal data is kept safe and secure.
When you provide us with personal data, you have certain legal rights, and these include:
To request access to, deletion of or correction of, your personal data held by us at no cost to you
To request that your personal data be transferred to another person (data portability)
To be informed of what data processing is taking place
To restrict processing
To object to processing of your personal data
To complain to a supervisory authority (you can do this in the UK at www.ico.org.uk)
If you wish to access, rectify, erase or transfer your personal data, please contact us at firstname.lastname@example.org
What happens when we link to other websites
Please note that our terms and conditions and our policies will not apply to other websites that you get to via a link from our Website. We have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
The changes we may make to this policy
We can update this policy from time to time as laws change or as our Services or Websites change. If we make material changes to the policy, and we need your consent to those changes, we will contact you by email to do so.