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This Data Processing Addendum (“DPA”) supplements the agreement between CircleCo, Inc (“Circle”) and the customer that agrees (or the customer on whose behalf an Administrator agrees) to the Circle Terms of Service (the "Customer") in relation to the transfer and processing of Covered Data in connection with the performance of the Services.
Customer | Circle | |
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Role | Data Exporter (controller) | Data Importer (processor) |
Contact person | The Administrator | Karthik Ganesh, Chief of Staff, legal@circle.so |
Activities relevant to the transfer | The receipt of the Services under the Agreement. | The performance of the Services under the Agreement. |
Categories of Data Subjects |
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Categories of Personal Data |
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Special categories of Personal Data | None |
Frequency of the transfer |
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Nature of the Processing |
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Purposes of the data transfer and further Processing |
Provision of the Services, namely:
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Retention period |
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Subprocessors | As set out in Schedule 4 |
The competent supervisory authority is: the Data Protection Commissioner (Ireland).
Categories of Data Subjects |
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Categories of Personal Data | Administrators
Where the Administrator is also the Customer:
Authorized Users
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Purposes of processing | Communication with Administrators (including sending service-related and promotional communications) Administration of the agreement with the Customer (including authentication and granting access to the Services, processing renewals, billing and processing payments, detection of fraudulent use) Promoting and marketing the Services. |
Categories of Data Subjects |
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Categories of Personal Data |
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Purposes of processing | Monitoring the performance of the Services, identifying errors and improvements to the Services and informing product development. |
Circle has a breach response plan that has been developed to address data breach events. The plan is tested and updated at least annually.
“Approved Addendum” means the template addendum, version B.1.0 issued by the UK Information Commissioner under S119A(1) Data Protection Act 2018 and laid before the UK Parliament on 2 February 2022, as it may be revised according to Section 18 of the Approved Addendum.
“UK Data Protection Laws” means all laws relating to data protection, the processing of personal data, privacy and/or electronic communications in force from time to time in the UK, including the UK GDPR and the Data Protection Act 2018.
In the event of a conflict or inconsistency between this Addendum and the provisions of the Clauses or other related agreements between the Parties, existing at the time this Addendum is agreed or entered into thereafter, the provisions which provide the most protection to Data Subjects will prevail.
To the extent that the data exporter's Processing of Personal Data is exclusively subject to Swiss Data Protection Laws, or the transfer of Personal Data from a data exporter to a data importer under the Clauses is an “onward transfer” (as defined in the Clauses, as amended by the remainder of this paragraph 3.3(a)) the following amendments are made to the Clauses:
100ms | ||
49095 Woodgrove Common, Fremont, CA 94539 | ||
N/A | N/A | N/A |
Live video (WebRTC and HLS) |
Amazon Web Services | ||
410 Terry Avenue North, Seattle, WA 98109 | ||
N/A | N/A | N/A |
Cloud Hosting |
Cloudflare | ||
101 Townsend Street, San Francisco, CA 94107 | ||
888-993-5273 | Joe Sullivan | privacyquestions@cloudflare.com |
Content Delivery Network |
Google Cloud Platform | ||
1600 Amphitheatre Pkwy, Mountain View, CA 94043 | ||
N/A | N/A | N/A |
Cloud Hosting |
Hubspot | ||
Two Canal Park, Cambridge, MA 02141, USA | ||
N/A | N/A | N/A |
CRM & Marketing |
Sendgrid | ||
Denver, Colorado | ||
N/A | Nick Francis | privacy@twilio.com |
Email Delivery Service |
Stripe | ||
510 Townsend Street, San Francisco, CA 94103 | ||
N/A | N/A | dpo@stripe.com |
Payments, Billing, and Invoices |
Zapier | ||
548 Market Street, Suite 62411, San Francisco, CA 94104 | ||
N/A | Wuk Kim | privacy@zapier.com |
App Automations |
Zendesk | ||
989 Market Street, San Francisco, CA 94103, United States | ||
N/A | Privacy Team | privacy@zendesk.com |
Customer Support |