Last updated September 16, 2024
OVERVIEW
This privacy notice for CRCLRT (“Company“, “we“, “us” or “our“), describes how and why we might collect, store, use, and/or share (“process“) your information when you use our services (“Services“), such as when you:
• Visit our website at https://circularity.marketing/• Engage with us in other related ways – including any sales, marketing, or events
Understanding the meaning of (“You“, “Your“, “Yourself” or “User“) we mean the entity you represent in accepting these Terms, or, if that does not apply, you individually that refers to you, the person who is entering into this Agreement with CRCLRT and to anyone who uses our Service, including general visitors to our Website. If you are accepting on behalf of your employer, your company, or another entity, you represent and warrant that (i) you have full legal authority to bind your employer or such entity to these Terms; (ii) you have read and understand these Terms; and (iii) you agree to these Terms on behalf of the party you represent.
Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at: circularitymkt@outlook.com.
PRIVACY POLICY IS PART OF OUR TERMS AND CONDITIONS OF USE
Our privacy policy is part of, and subject to, our website’s Terms of Service.
SUMMARY OF KEY POINTS
This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.
What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with CRCLRT and the Services, the choices you make, and the products and features you use.
Do we process any sensitive personal information? We do not process sensitive personal information.
Do you receive any information from third parties? We do not receive any information from third parties.
How do you process my information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.
In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties.
How do we keep your information safe? We have organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.
What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.
How do I exercise my rights? The easiest way to exercise your rights is by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.
Want to learn more about what CRCLRT does with any information we collect? Going through the SECTIONS below.
1. WHAT INFORMATION DO WE COLLECT?
Personal information you disclose to us through our Services, and/or through third-party websites we may use specifically for marketing purpose only, CRM platform (Hubspot).
In short: We collect personal information that you provide to us through our Services.
We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include such as your name and last name, username, password, phone and mobile number, email addresses, job titles, contact preferences.
Sensitive Information. We do not process sensitive information.
Payment Data. We do not collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as payment card type, payment expiration date, payment type, credit card number, billing address, contact or authentication data, security code, tax id, company registration number, etc) associated with your payment-related information, your bank account directly, and the payment processors, as described follow. All payment data is stored through third-party websites we may use specifically and for payment purpose only, payment processing platforms (Stripe and/or Paypal), interlinking/integrating certain specific information credentials (such as username, password and email) required through third-party websites we may use specifically specifically and for marketing purpose only, CRM platform (Hubspot) by finishing your payment process and give you access to service. The necessary specific information credential (email) are sent and manage through our third-party email system (Microsoft Outlook).
We do not have control over third-party tools or integrations, and you expressly acknowledge that We are not responsible for the privacy practices associated with such tools and integrations. You may find their privacy notice link(s) here:
• Stripe• Paypal
• Hubspot
• Microsoft Outlook
Social Media Login Data. Some of third-party websites may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter, Linkedin or other social media account. If you choose to register in this way, we and/or through third-party websites we may use, will collect the information described in the section called “HOW DO WE HANDLE YOUR SOCIAL LOGINS?” below.
All personal information that you provide to us and/or through third-party websites we may use must be true, complete, and accurate, and you must notify us and/or through third-party websites we may use of any changes to such personal information.
Information automatically collected
In short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies. You can find out more about in our section “DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?” below.
The information we collect includes:
• Log and Usage Data: Log and usage data is service-related, diagnostic, usage, and performance information our server automatically collects when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).• Device Data: Device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location Data: Location data such as information about your device’s location, which can be either precise or imprecise. How much information collect depends on the type and settings of the device you use to access the Services. For example, can use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.
2. HOW DO WE PROCESS YOUR INFORMATION?
In short: We and/or through third-party websites we may use specifically for marketing purpose only, CRM platform (Hubspot) process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.
We and/or through third-party websites we may use specifically for marketing purpose only, CRM platform (Hubspot) process your personal information for a variety of reasons, depending on how you interact with our Services, including:
• To facilitate account creation and authentication and otherwise manage user accounts: Some of third-party websites we may use may process your information so you can create and log in to your account, as well as keep your account in working order. All of your account management and settings are fully managed directly under third-party websites we may use.• To deliver and facilitate delivery of services to the user: We may process your information to provide you with the requested service.
• To respond to user inquiries/offer support to users: We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service. Support form submissions are sent to our third-party Hubspot ticketing system. Information submitted through the contact form on our website is sent to our third-party Microsoft Outlook email system.
• To enable user-to-user communications: We may process your information if you choose to use any of our offerings that allow for communication with another user.
• To request feedback: We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To send you marketing and promotional communications: We may process the personal information you send to us and/or through third-party websites we may use for our marketing purpose interlinked with other third-party website we may use specifically for marketing purpose only, the CRM platform (Hubspot), if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see “WHAT ARE YOUR PRIVACY RIGHTS?” below.
• To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more. For more information visit the section “DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?” below.
• To protect our Services: We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends: We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
• To save or protect an individual’s vital interest: We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.
All of list below adhere to the EU/US “Privacy Shield” and you may find their privacy notice link(s) here:
• Hubspot• Microsoft Outlook
3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.
If you are located in the EU or UK, this section applies to you.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:
• Consent: We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time.• Performance of a Contract: We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Legitimate Interests: We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
• Send users information about special offers and discounts on our products and services
• Develop and display personalized and relevant advertising content for our users
• Analyze how our services are used so we can improve them to engage and retain users
• Support our marketing activities
• Diagnose problems and/or prevent fraudulent activities
• Understand how our users use our products and services so we can improve user experience
• Legal Obligations: We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests: We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.
You can find more information on EU GDPR Information Portal.
If you are located in Canada, this section applies to you.
We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.
In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:
• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kind
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations
4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We do not share your data with third parties in a way as to reveal any of your personal information like email, name, etc. We may share limited data information in specific situations described in this section and/or with the following third parties in order to provide the services you expect from us.
We may need to share your personal information in the following situations:
• Integrated Providers. We may share your information with certain third-party integrated providers to interact on our websites, providing marketing assistance, supplementing the information you provide us in order to provide you with better service.• Third-Party Providers: We may share your information with certain third-party content management system, payment processors, and other service providers that provide us with certain services and process personal information on our behalf.
• Advertising and Analytics Partners: We may share your information with certain third-party advertisers, advertisement networks, and analytics providers through cookies and other similar technologies.
We obtain and store on your device (‘cache’) your location for one (1) month. You may revoke your consent anytime by contacting us at the contact details provided at the end of this document. For further information, please visit our section “DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?” below.
We recommend that you read the privacy policies of those third party services to understand how they collect, use, and share your personal information. You may find their privacy notice link(s) here:
• Google Maps• Google Analytics
You may find more privacy notice link(s) in our section “HOW DO WE PROCESS YOUR INFORMATION?” above.
5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store your information.
We may use cookies and similar tracking technologies (like web beacons, JavaScript and pixels) to access or store information, to analyze trends, administer the website, monitor how visitors navigate around the websites, gather demographic information about our user base as a whole, and customize our website content for you as an individual. Specific information about how we use such technologies and how you can refuse certain cookies is set out here in this section.
What are cookies?
Cookies are small data files that our website asks your browser to store on your computer or mobile device when you visit our website. Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information. Generally, it contains certain information that is not personally identifiable to you, but is used to improve and personalize your web experience. For example, when you visit the site again, the cookie allows that site to recognize your browser. Cookies may store user preferences and other information. Cookies provide a convenience feature to save you time, or tell the Web server that you have returned to a specific page.
Cookies set by the website owner (in this case, https://circularity.marketing/) are called “first party cookies”. Cookies set by parties other than the website owner are called “third party cookies”. Third party cookies enable third party features or functionality to be provided on or through the website (e.g. like advertising, interactive content and analytics). The parties that set these third party cookies can recognize your browser/computer both when it visits the website in question and also when it visits certain other websites.
Why do we use cookies?
We use first and third party cookies for several reasons. Some cookies are required for technical reasons in order for our Websites to operate, and we refer to these as “essential” or “strictly necessary” cookies. Other cookies also enable us to track and target the interests of our users to enhance the experience on our Online Properties, Websites, and Marketplace Offerings. For example, CRCLRT keeps track of the Websites and pages you visit within CRCLRT, in order to determine what portion of the CRCLRT Website or Marketplace Offerings are the most popular or most used. This data is used to deliver customized content and promotions within the CRCLRT Website and Marketplace Offerings to customers whose behavior indicates that they are interested in a particular subject area. Third parties serve cookies through our Websites for advertising, analytics and other purposes. This is described in more detail below.
The specific types of first and third party cookies served through our Websites and the purposes they perform are described below (please note that the specific cookies served may vary depending on the specific Online Properties, Websites, and Marketplace Offerings you visit).
How can I control cookies?
You have the right to decide whether to accept or reject cookies. You can exercise your cookie rights by setting your preferences in the Cookie Consent Manager. The Cookie Consent Manager allows you to select which categories of cookies you accept or reject. Essential cookies cannot be rejected as they are strictly necessary to provide you with services.
The Cookie Consent Manager can be found in the notification banner and on our website. If you choose to reject cookies, you may still use our website though your access to some functionality and areas of our website may be restricted. You may also set or amend your web browser controls to accept or refuse cookies. As the means by which you can refuse cookies through your web browser controls vary from browser-to-browser, you should visit your browser’s help menu for more information. For more information, see “How do I manage, control or block cookies?” below.
In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit http://www.aboutads.info/choices/ or http://www.youronlinechoices.com. You may opt out by clicking here: http://optout.aboutads.info/ or http://optout.networkadvertising.org/ (or if located in the European Union, by clicking here: http://www.youronlinechoices.eu/). Please note this does not opt you out of being served advertising. You will continue to receive generic advertisements.
How do I manage, control or block cookies?
You can manage your preferences regarding Cookies by modifying them in the designated “Cookie Settings” pop-up tool on our website. You can opt-out of each cookie category (except strictly necessary cookies) by clicking on the corresponding category and disabling it.
You can also modify your Cookie preferences directly from your browser. Almost all browsers allow to detect Cookies and block them automatically. Please note that if you disable our website Cookies or Cookies in general in your browser settings, this will prevent Website functionally-required cookies and certain sections or features of our Website will not work.
All browsers (Google Chrome, Internet Explore, FireFox, etc.) allow the user, when visiting or accessing a website, to accept, refuse or erase cookies, namely by selecting the appropriate definitions. Browser settings are usually found in the ‘Options’ or ‘Preferences’ menu. Browser-specific help with cookies can be found in the links below. For further information, we recommend referring to the documentation of your browser.
• Microsoft Edge• Chrome
• Firefox
• Safari
• Opera
What types of cookies do we use and how do we use them?
The specific types of first and third party cookies managed, served by us or third-parties through our Websites, serve various purposes on our Website. Based on purpose, they can be either essential for the functioning of our Online Properties, Websites, and Marketplace Offerings or enable us with extra functionality such as tracking trends and movements of the users, analyzing demographic information, provide performance and analytic data about the Website and serve advertising. Based on the purpose they perform are described below (please note that the specific Online Properties, Websites, and Marketplace Offerings you visit).
Essential website cookies:
These cookies are strictly necessary for our Website to function and provide you with services available through our Websites, Marketplace Offerings and to use some of its features, such as navigating and enabling certain functioning of our Websites access to secure areas, offer improved and more personalized services, products and other relevant communication tailored to you, etc. You cannot manage or be switched off this type of cookies in our system and to disable them, you’ll need to switch them off across-the-board in your browser settings. You can set your browser to block or alert you about these cookies, but please note that some parts of our Website will not work in this case. These cookies do not store any personally identifiable information.
Performance and functionality cookies:
These cookies are used to enhance the performance and functionality of our Websites but are non-essential to their use. However, without these cookies, certain functionality (like videos) may become unavailable. Performance cookies generate aggregated, de-identified information which provide insights into trends and usage patterns that may be used for business analysis, website and service improvements, and for determining performance metrics. Functional cookies enable our website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.
Selection cookies:
These cookies used to remember your selections while visiting our Website. These types of cookies allow our Website to recognize your device so that you do not have to provide the same information repeatedly. For example, we may use cookies to identify the visitor’s current language, the last visited language and the language of users who have logged in. No data from the user itself will be shared.
Analytics and customization cookies:
These cookies collect information that is used either in aggregate form to help us understand how our Websites are being used or how effective our marketing campaigns are, or to help us customize our Websites for you. We use analytics services by third parties to collect information about the use of our Website to measure and improve our Website performance. All information these cookies collect is aggregated and therefore anonymous. If you disable these cookies we will not know when you have visited our site, and will not be able to monitor and improve its performance.
Advertising and targeting cookies:
These cookies are used to help us to develop and target advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and in some cases selecting advertisements that are based on your interests. These types of third-party cookies enable us to understand what ads you see and interact with, both on our Website and on third-party websites. As a result we may display targeted, or interest-tailored offers based on the products you currently own or have recently viewed and deliver other communication more relevant to you and your interests outside of our Website, on other websites part of the third party’s network. As part of this process, we do not disclose your personal information to the third-party website. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.
Social networking cookies:
These cookies are used to enable you to share pages and content that you find interesting on our Websites through third party social networking and other websites. These cookies may also be used for advertising purposes.
What about other tracking technologies, like web beacons?
Cookies are not the only way to recognize or track visitors to a website. We may use other, similar technologies from time to time, like web beacons (sometimes called “tracking pixels”, “clear gifs”, “image tags” or “script tags”) that help us better manage our Website by informing us what content is effective. They are small files or pieces of code that may be loaded on our Website and they are used in conjunction with cookies. These clear gifs are tiny graphics files that contain a unique identifier, similar in function to cookies, and are used to track the online movements of Web users that enable us to recognize when someone has visited our Websites or opened an e-mail including them. Generally found within website pages that allow website providers to understand users’ browsing activities, or in our HTML-based emails to let us know which emails have been opened by recipients. This allows us, for example, to monitor the traffic patterns of users from one page within a website to another, to deliver or communicate with cookies, to understand whether you have come to the website from an online advertisement displayed on a third-party websites, to improve site performance, and to measure the success of e-mail marketing campaigns. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will impair their functioning.
Do you serve targeted advertising?
Third parties may serve cookies on your computer or mobile device to serve advertising through our Websites. These companies may use information about your visits to this and other websites in order to provide relevant advertisements about goods and services that you may be interested in. They may also employ technology that is used to measure the effectiveness of advertisements. This can be accomplished by them using cookies or web beacons to collect information about your visits to this and other sites in order to provide relevant advertisements about goods and services of potential interest to you. The information collected through this process does not enable us or them to identify your name, contact details or other details that directly identify you unless you choose to provide these.
How often will you update this Cookies Policy?
We may update this Cookie Policy from time to time in order to reflect, for example, changes to the cookies we use or for other operational, legal, regulatory reasons or in the interpretation by the relevant data protection laws. Please therefore re-visit this Cookie Policy regularly to stay informed about our use of cookies and related technologies.
The date at the top of this Cookie Policy indicates when it was last updated.
Where can I get further information?
If you have any questions about our use of cookies, other technologies or if you would like to contact us with your views about our privacy practices, or with any enquiry relating to your personal information, please email us at circularitymkt@outlook.com
6. HOW DO WE HANDLE YOUR SOCIAL LOGINS?
In Short: If you choose to register or log in to our services through third-party websites we may use by using a social media account, we may have access to certain information about you.
Our Services offer you the ability to register and log in using your third-party social media account details (like your Facebook, Twitter or Linkedin logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.
We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.
You may find their privacy notice link(s) here:
• Facebook7. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process your information in countries other than your own.
Our server is located in HubSpot, hosted on Amazon Web Services (AWS) in the United States East region or AWS in the Germany region. If you are accessing our Services from outside the United States (US) or Germany (DE), please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information (see “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?” above), in other countries.
If you are a resident in the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy notice and applicable law.
Our hosting provider HubSpot ensures that your data is securely stored and GDPR compliant. You can find more information on HubSpot GDPR Compliance.
8. HOW LONG DO WE KEEP YOUR INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
9. HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.
We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.
Some of technical and security measures we have implemented on daily basis to keep our website safe to prevent malware, brute force, exploits and other malicious actions, are:
• SSL Manager: SSL is crucial for the security of our website through SSL certificate encrypts all traffic that goes through our website• HTTPS Enforce: Used to enforce our website to work over an encrypted and secure HTTPS connection where is performed on a server level and works for our website with active SSL
• DDoS attack: Analyzes and confirm how traffic behave coming from our
• Norton Safe Web: Analyzes our website process to ascertain and classifies based on how safe our website is to visit and rating our website’ safety level
10. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at: circularitymkt@outlook.com
11. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.
In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.
We will consider and act upon any request in accordance with applicable data protection laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here.
If you are located in Switzerland, the contact details for the data protection authorities are available here.
Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below or updating your preferences.
However, please note that this will not affect the lawfulness of the processing before its withdrawal, nor when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us using the details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below. You will then be removed from the marketing lists — however, we and/or through third-party website we may use specifically and for marketing purpose only, CRM platform (Hubspot) may still communicate with you, for example to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.
Please note that opting out of marketing and promotional communications only affects future communications from us, however through third-party websites, you may have to change your preferences directly with that third parties.
Account Information
If you would at any time like to review or change the information in your account or terminate your account, you can:
• Log in to your account settings and update your user account.Upon your request to terminate your account, we and/or through third-party websites we may use will deactivate or delete your account and information from our active databases. However, we and/or through third-party websites we may use may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
All of your account management and settings are fully managed directly under third-party websites we may use.
Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. To opt out of interest-based advertising by advertisers on our Services visit http://www.aboutads.info/choices/. For further information, please visit our section “DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?” below.
If you have questions or comments about your privacy rights, you may email us at: circularitymkt@outlook.com
12. CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.
13. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section § 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).
CCPA Privacy Notice
The California Code of Regulations defines a “resident” as:
• every individual who is in the State of California for other than a temporary or transitory purpose and• every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose
All other individuals are defined as “non-residents.”
If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.
What categories of personal information do we collect?
We have collected the following categories of personal information in the past twelve (12) months:
• Identifiers: Contact details, such as real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, and account name.• Protected classification characteristics under California or federal law: Gender and date of birth.
• Internet or other similar network activity: Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements.
• Geolocation data: Device location.
• Inferences drawn from other personal information: Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics.
We may also collect other personal information outside of these categories instances where you interact with us in person, online, or by phone or mail in the context of:
• Receiving help through our customer support channels;• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries.
How do we use and share your personal information?
More information about our data collection and sharing practices can be found in this privacy notice provided in the section “DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?” below.
You may contact us by email at: circularitymkt@outlook.com
If you are using an authorized agent to exercise your right to opt out we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information.
CRCLRT has not disclosed or sold any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. CRCLRT will not sell personal information in the future belonging to website visitors, users, and other consumers.
Your rights with respect to your personal data
Right to request deletion of the data — Request to delete
You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
Right to be informed — Request to know
Depending on the circumstances, you have a right to know:
• whether we collect and use your personal information;• the categories of personal information that we collect;
• the purposes for which the collected personal information is used;
• whether we sell your personal information to third parties;
• the categories of personal information that we sold or disclosed for a business purpose;
•the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and
• the business or commercial purpose for collecting or selling personal information.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
We will not discriminate against you if you exercise your privacy rights.
Verification process
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
Other privacy rights
• You may object to the processing of your personal information.• You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information.
• You can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.
• You may request to opt out from future selling of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.
To exercise these rights, you can contact us by email at: circularitymkt@outlook.com. If you have a complaint about how we handle your data, we would like to hear from you.
14. DO WE MAKE UPDATES TO THIS NOTICE?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.
15. HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
If you have questions or concerns about this notice, or if you have a disability and need to access this notice in a different format, you may contact us at:
CRCLRT – Representative Office
Recife-PE
Brazil
email: circularitymkt@outlook.com
16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it in some circumstances at any time. To request to review, update, or delete your personal information, please submit a request by contacting us.