Circu Privacy Policy – Last updated June 4, 2018


Summary
This page informs you of our policies regarding the collection, use and disclosure of personal information we receive from users of this site.
Circu collects your data strictly to provide you with access to our news, special campaigns and events. We will not share this data with anyone unless you explicitly consent to us doing so. We honor your right to privacy and will comply with your wishes to remove your data from our systems.
This Privacy Policy only covers information collected through this site and does not cover any information collected offline by us, including information collected by our 3rd Party Wholesale Retail partners.
We use your Personal Information only for providing and improving this site. By using this site, you agree to the collection and use of information in accordance with this policy.

Our core beliefs regarding user privacy and data protection
- User privacy and data protection are human rights.
- We have a duty of care to the people within our data.
- Data is a liability, it should only be collected and processed when absolutely necessary.
- We loathe spam as much as you do!
- We will never sell, rent or otherwise distribute or make public your personal information.

Relevant legislation
Along with our business and internal computer systems, this website is designed to comply with the following legislation with regards to data protection and user privacy: EU General Data Protection Regulation 2018 (GDPR)

Personal information that this website collects and Use
This website collects and uses personal information for the following reasons:

Site visitation tracking
Like most websites, this site uses Google Analytics (GA) to track user interaction. We use this data to determine the number of people using our site, to better understand how they find and use our web pages and to see their journey through the website.
Although GA records data such as your geographical location, device, internet browser and operating system, none of this information personally identifies you to us. GA also records your computer’s IP address which could be used to personally identify you but Google do not grant us access to this. We consider Google to be a third party data processor.
GA makes use of cookies, details of which can be found on Google’s developer guides.
Disabling cookies on your internet browser will stop GA from tracking any part of your visit to pages within this website.

Our blog
Should you choose to add a comment to any posts that we have published on our blog, we use Disqus to handle your data. We consider Disqus to be a third party data processor. Disqus privacy policy can be found here.
NOTE: You should avoid entering personally identifiable information to the actual comment field of any blog post comments that you submit on this website.

Contact forms and email links
Should you choose to contact us using the contact form on our Contact us page or an email link like this one, none of the data that you supply will be passed to be processed by any of the third party data processors mentioned. The data will be collated into an email and sent to us over the Simple Mail Transfer Protocol (SMTP).
Our own SMTP servers are protected by TLS (sometimes known as SSL). However, not all mail servers are secured in such a way. Therefore, we would suggest that you always consider email as an insecure medium and not include personal, confidential or otherwise sensitive information within an email.

Across our web platforms, you will be presented with the opportunity to sign up for newsletters, submit your information to access content such as prices, technical information of our products, and apply for eligibility to certain events and special campaigns. We use the data you provide to us for the following purposes:
- Provide you with access to the content and campaigns we produce.
- Analyze profile or behavioral data to help us improve the products we offer to you.
We will store this information to keep you informed about other relevant products that may be useful to you.
We will never use or share the information provided to us online in ways unrelated to the ones described above.

Some information, such as IP and your email address, may be shared with the following third parties who help us run our website and email programs. They will only use this information to serve our needs and are prohibited from using it in any other instance. They are:
Salesforce (CRM - customer relationship management software)
Facebook and Instagram (ad serving)
Zendesk (chat and help desk).

Email newsletter
If you choose to join our email newsletter, the email address that you submit to us will be forwarded to MailChimp who provide us with email marketing services. We consider MailChimp to be a third party data processor.
Your email address will remain within MailChimp’s database for as long as we continue to use MailChimp’s services for email marketing or until you specifically request removal from the list. You can do this by unsubscribing using the unsubscribe links contained in any email newsletters that we send you or by requesting removal via email. When requesting removal via email, please send your email to us using the email account that is subscribed to the mailing list.
If you are under 16 years of age you MUST obtain parental consent before joining our email newsletter.
While your email address remains within the MailChimp database, you will receive periodic newsletter-style emails from us.

Failure to Provide Consent
Consenting to allow us to process and store your data is optional. However, failure to provide that consent will prevent us from delivering the content, campaigns and other experiences to you as mentioned above.

Cookies
Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer's hard drive.
Like many sites, Circu uses "cookies" to collect information. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our site.

Your Rights
At any time, you have the right:
- to request access to or a copy of any information which we hold about you;
- to rectification of your information, if you consider that it is inaccurate;
- to ask us to delete your information, if you consider that we do not have the right to hold it;
- to withdraw consent to our processing of your information (to the extent such processing is based on previously obtained consent);
- to ask us to stop or start sending you marketing messages;
- to object to your information being processed in certain circumstances.

Any request for access to or a copy of your information must be in writing and we will endeavour to respond within a reasonable period and in any event within one month in compliance with data protection legislation. We will comply with our legal obligations as regards your rights as a data subject.

How long will we keep your information?
We will keep your information for as long as you have your account, or as long as is needed to be able to provide the services to you, or (in the case of any contact you may have with us) for as long as is necessary to provide support-related reporting.
If reasonably necessary or required to meet legal or regulatory requirements, resolve disputes, prevent fraud and abuse, or enforce our Terms and Conditions, we may also keep hold of some of your information as required, even after you have closed your account, or it is no longer needed to provide the services to you.
Where we are permitted to send you direct marketing communications we may retain your contact information necessary for this purpose, (if you have consented to receiving them) for as long as you do not unsubscribe from receiving the same from us.

Security
The security of your Personal Information is important to us but, remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

Our Commitment to The Security of Your Data
To prevent unauthorized parties from accessing your data and maintain the accuracy and cleanliness of our own data while ensuring the correct use of it, we have put in place appropriate physical, electronic and managerial procedures to safeguard and secure the information we collect online.

Specific Issues for The Disclosure of Personal Data To Third Parties
Circu respects that the personal data you have provided us is confidential. With that in mind, we will not disclose your personal data to other third parties without obtaining your permission first.

Changes to This Privacy Policy
This Privacy Policy is effective as of May 23 and will remain in effect except with respect to any changes in its provisions in the future, which will be in effect immediately after being posted on this page.
We reserve the right to update or change our Privacy Policy at any time and you should check this Privacy Policy periodically. Your continued use of the Service after we post any modifications to the Privacy Policy on this page will constitute your acknowledgment of the modifications and your consent to abide and be bound by the modified Privacy Policy.

How to Ask Us to Delete Your Data
If you would like to unsubscribe from our communications at any time, you may do so in the footer of our emails or replying directly to the email sent to you. If you would like us to delete your information entirely, or request the information we store about you, contact us at info@circu.net. Otherwise, by continuing to interact with our emails and services, you provide us with permission to manage and use your data as described above.

Contact Us
Questions about our privacy policy or how we use data? Email us directly at: info@circu.net.


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