Privacy Policy

Version 1.3 In force from 13/10/2020

Last updated in October 2020

Introduction

Circeular Partners Limited (“Circeular”) is committed to protecting and respecting your privacy. We want to tell you how we use and protect your personal information. This includes informing you of your rights regarding your personal information that we hold.

To ensure transparency, this Privacy Policy describes our information handling practices when you access content we own or operate on the website www.Circeularpartners.com

This Privacy Notice sets out how we may use, process and store your personal information. We may get that information from you or our partners, through contracts or other legal arrangements you have with us or our partners on behalf of us in order to deliver contractual/legal obligations. In other cases, we will get that information from you with your permission and consent, or we may receive your personal information from third parties who you have given consent to pass this information on to us.

The Laws and Regulations

The laws that govern personal data in the IOM are:

The Data Protection Act 2002

REGULATION (EU) 2016/679 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (“GDPR”).

The independent authority that upholds information rights in the public interest in the Isle of Man is the Isle of Man Information Commissioner. Further information can be found at https://www.inforights.im/

Who is Circeular Partners Limited?

This is Circeular’s trading address, company number and contact information:

Circeular Partners Limited
19-21 Circular Road,
Douglas,
Isle of Man,
IM1 1AF

Company Registration Number: 133522C

Email: [email protected]

Phone: +44 (0) 1624 604270

Circeular’s Website: http://www.Circeularpartners.com

Information we may collect from you

Circeular collects personal information about you whenever you use our services. Some of it is information you give us directly when, for example, you email us. Other information is collected as you interact with us, such as online chats with our customer services team.

Information you give us

You may give us information about you with your consent, for example:

· By filling in a form or sending us an e-mail

· Applying for a job at Circeular

This information may be personal, financial, educational, or related to your employment history.

Cookies

This website uses cookies. We use cookies to analyze website traffic and optimize your website experience. By accepting our use of cookies, your data will be aggregated with all other user data.

Why does Circeular collect personal information?

Circeular collects information for some or all of the following reasons:

· To provide services to you after you have registered an account

· To employ you or consider you for employment

· For legal or regulatory reasons, for example, if you have entered into a contract with us

· Things we do with your consent for marketing purposes

What legal basis does Circeular have for processing my information?

Circeular may process your information because:

· We have a contract with you

· You have given us permission to do so

· We must provide services to you after you have registered an account

· To comply with the law.

All of these reasons are reasons Circeular may legally process the information we have about you.

Who might Circeular share your information with?

We share your personal information with external organisations that carry out a range of services on behalf of Circeular. We carry out checks to ensure that the companies we work with will give your information the same level of care and protection as we do. Both we and they are obliged to handle your information in accordance with data protection law, and we are also required to put in place contractual measures reinforcing those obligations.

The main functions that are or may be carried out, fully or in part, by third parties are listed below:

· Account set-up and registration

· Management and execution of marketing campaigns

· Customer services

· Payment processing and verification

· Anti-fraud and -money laundering checks and ID verification

· Checks to detect unfair use of our products and services

· Web hosting, online content services and data storage

· Management of competitions, contests and offers

· Data analytics and data cleansing

· Market research and collecting or analysing customer feedback

· IT services and support

· Audit-, Legal- & Compliance- related services

Where we store your personal data

We primarily store and process your personal data in the Isle of Man. If we do transfer your personal data outside the EEA it will be because you have consented or because we have a legal reason to do so.

Some examples of reasons your data may be processed outside of the EEA include:

· Services fulfilment

· Verification processing

· Payment processing

· Technical support services.

If your personal data cannot be processed within the EEA, we will:

· Comply with all other data protection principles

· Where possible, be to a country that is on the list of the EU Commissions’ countries that provide adequate protections for the rights and freedoms of data subjects

· If the transfer is to the United States of America, we will use reasonable endeavours to make sure they participate in the Privacy Shield program

· Make sure we have assessed the adequacy of protections in all other cases.

Access to your stored personal data via password

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Transmission and storage of your personal data

Unfortunately, the transmission of information via the internet is not completely secure. Although we use best practice to ensure your data is encrypted to the standard required in the GDPR to protect your personal data, we cannot guarantee the security of your data as it is transmitted and stored.

How long will you keep my personal information?

Circeular will not retain your personal information for longer than required. We will keep your personal information:

· For as long as required by law

· Until we no longer have a valid reason for keeping it

· Until you request us to stop using it.

· We may keep just enough of your personal information to ensure that we comply with your requests to not use your personal information or comply with your right to erasure. For example, we must keep your request to be erased even if it includes your personal data until such time as you are no longer our customer.

If you have questions about our Data Retention Policy, we can provide you a copy. Please contact: [email protected]

What if I chose not to give you my personal information?

If the personal information is necessary in order to supply services to you under a contract between you and Circeular, then we will not enter into that contract or provide the services if you do not give us your personal information.

Your Rights

Circeular will respect your legal rights to your data.

Below are the rights that you have under law, and what Circeular does to protect those rights:

The right to be informed

Circeular is publishing this Privacy Notice to keep you informed as to what we do with your personal information. We strive to be transparent about how we use your data.

The right to access

You have the right to access your information. Please email Circeular’s Data Protection Officer at [email protected] if you wish to request a Subject Access Request which shows all information Circeular holds about you. This information will be provided to you within 30 days of your request.

The right to rectification

If the information Circeular holds about you is inaccurate or not complete, you have the right to ask Us to rectify it. If that data has been passed to a third party with your consent or for legal reasons, then we must also ask them to rectify the data. Please contact our Data Protection Officer if you need us to rectify your information: [email protected]

The right to restrict processing

You have the right to ask Circeular to restrict how we process your data. This means We are permitted to store the data but not further process it. We keep just enough data to make sure we respect your request in the future. If you want us to restrict processing of your data, please contact our Data Protection Office: [email protected]

The right to data portability

Circeular must allow you to obtain and reuse your personal data for your own purposes across services in a safe and secure way without this effecting the usability of your data. Please contact our Data Protection Officer if you want information on how to port your data elsewhere: [email protected]. This right only applies to personal data that you have provided to Us as the Data Controller. The data must be held by Us by consent or for the performance of a contract.

The right to object

You have the right to object to Circeular processing your data even if it is based on Our legitimate interests, the exercise of official authority, direct marketing (including data aggregation), and processing for the purposeless of statistics. If you wish to object please contact our Data Protection Officer: [email protected]

The right to withdraw consent

If you have given us your consent to process your data but change your mind later, you have the right to withdraw your consent at any time, and Circeular must stop processing your data. If you want to withdraw your consent, please contact our Data Protection Officer: [email protected]

The right to complain to a Supervisory Authority

You have the right to complain to the ICO if you feel that Circeular has not responded to your requests to solve a problem. You can find their contact details here: https://www.inforights.im/

Links to Other Websites

From time to time, our website may contain links to and from websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites may have their own privacy notices and that we do not accept any responsibility or liability for any such notices. Please check these notices, where available, before you submit any personal data to these websites.

Changes to Our Privacy Notice

Circeular may change this notice from time to time in the future. Any such changes will be posted here and, where appropriate, notified to you in writing. We advise you to check back frequently to see any updates or changes.

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