This European Privacy policy contains information on how we collect, store, process, transfer, share use data that identifies or is associated with residents of the European Economic Area (“EEA”), Switzerland, and the United Kingdom (“UK”) (“personal data”) and information regarding our use of cookies and similar technologies. This European Privacy Policy applies solely to residents of the EEA, Switzerland, and the UK (“you”). Please ensure that you have read and understood this European Privacy Policy before accessing or using the Website, App, or Services. Unless otherwise expressly stated, all terms in this section have the same meaning as defined in our Privacy Policy or as otherwise defined in the General Data Protection Regulation (“GDPR”).
We process most of the personal data that customers and their users upload to the Services as a processor on behalf of the relevant customer. This means that the relevant customer determines and is responsible for how we process that personal data. If a customer has uploaded your personal data to our Services, you should consult that customer's privacy notice (either on their website or as otherwise provided to you) for information about how that personal data is used.
We do, however, process some personal data as a controller as described in our Privacy Policy and this European Privacy Policy. This means that, with respect to the processing of personal data described in our Privacy Policy and this European Privacy Policy, CircleCo, Inc determines and is responsible for how your personal data is used.
Please contact legal@circle.so if you have any questions, comments and requests regarding this European Privacy Policy.
When you contact us to express an interest in our Services or with a query about becoming a customer of our Services, we will collect the following personal data:
| How we use it | Lawful basis we rely on |
|---|---|
| We use this information to communicate with you, including responding to your queries, comments or requests for further information about our Services. | The processing is necessary for our legitimate interests, namely communicating with prospective customers. |
| We use this information to send you promotional emails in accordance with your preferences. | We will only use your personal data in this way to the extent you give us your consent to do so. |
| How we use it | Lawful basis we rely on |
|---|---|
| We use this information to address your questions, issues and concerns. | The processing is necessary for our legitimate interests, namely communicating with prospective customers. |
When you sign up for a free trial, we will collect your contact information, such as your name and email address and the date on which you signed up for a free trial.
| How we use it | Lawful basis we rely on |
|---|---|
| We use this information to communicate with you, including responding to your queries, comments or requests for further information about our Services. | The processing is necessary for our legitimate interests, namely communicating with prospective customers. |
| We use this information to send you promotional emails in accordance with your preferences. | We will only use your personal data in this way to the extent you give us your consent to do so. |
When you sign up to our Services as a customer, or if a customer designates you as an admin user on their account, we will collect the following personal data:
| How we use it | Lawful basis we rely on |
|---|---|
| We use this information to communicate with you about the customer's account, including responding to your queries, comments or requests for further information about our Services, or sending you service-related communications (such as billing information and renewal reminders). | The processing is necessary for our legitimate interests, namely communicating with customers and administering agreements with customers. |
| We use this information to send you promotional emails in accordance with your preferences. | We will only use your personal data in this way to the extent you give us your consent to do so. |
| If you are the customer, (i.e. if you sign up to the Services as a customer in your personal capacity rather than as an admin on behalf of a customer), we use this information to set up and authenticate your account on the Services. | The processing is necessary for the performance of a contract with you, namely our Terms of Service. |
| How we use it | Lawful basis we rely on |
|---|---|
| We use this information to populate your profile on the Services. | The processing is necessary for the performance of a contract with you, namely our Terms of Service. |
If you are the customer (i.e. if you sign up to the Services or a free trial as a customer in your personal capacity rather than as an admin on behalf of a customer), we will also collect the following information:
| How we use it | Lawful basis we rely on |
|---|---|
| We use this information to populate your profile on the Services. | The processing is necessary for the performance of a contract with you, namely our Terms of Service. |
| How we use it | Lawful basis we rely on |
|---|---|
| We use this information to authenticate you and give you access to the Services. | The processing is necessary for the performance of a contract with you, namely our Terms of Service. |
| How we use it | Lawful basis we rely on |
|---|---|
| We use this information to process payments for the Services. | The processing is necessary for the performance of a contract with you, namely our Terms of Service. |
| We use this information to verify your identity in connection with the detection and prevention of fraud or financial crime. | The processing is necessary for our and third parties' legitimate interests, namely the detection and prevention of fraud and financial crime. |
| How we use it | Lawful basis we rely on |
|---|---|
| We use this information to provide you the features and functionality of the Services. | The processing is necessary for the performance of a contract with you, namely our Terms of Service. |
| We use this information to tailor the content of the promotional emails we send to you. | The processing is necessary for our and third parties' legitimate interests, namely informing our marketing strategy. |
| How we use it | Lawful basis we rely on |
|---|---|
| We use this information to authenticate you and allow you to log in to your account on the Services. | The processing is necessary for the performance of a contract with you, namely our Terms of Service. |
| How we use it | Lawful basis we rely on |
|---|---|
| We use this information to identify ways in which we can improve our Services, such as identifying errors and potential new features and functionalities. | The processing is necessary for our legitimate interests, namely identifying and resolving errors and informing our product development. |
| How we use it | Lawful basis we rely on |
|---|---|
| Remove such content. | The processing is necessary to comply with a legal obligation to which we are subject (to the extent that obligation arises under UK, EU or Member State law). Otherwise, the processing is necessary for our legitimate interests, the interests of our users and the public, namely ensuring that the Services are not used to distribute harmful or illegal material. |
| Report such content to applicable law enforcement authorities. | The processing is necessary to comply with a legal obligation to which we are subject (to the extent that obligation arises under UK, EU or Member State law). Otherwise, the processing is necessary for our legitimate interests, the interests of our users and the public, namely ensuring that the Services are not used to distribute harmful or illegal material. |
| How we use it | Lawful basis we rely on |
|---|---|
| We do not monitor how individuals interact with us on social media; however, we may use this information to respond to your comments or posts that are addressed to us or reference us. | The processing is necessary for our legitimate interests, namely promoting our Services through operating our social media page. |
We also automatically collect personal data indirectly about how you access and use the Website, App, or Services, and information about the device you use to access the Website, App, or Services, or otherwise engage with us. We collect the following information in this way:
| How we use it | Lawful basis we rely on |
|---|---|
| We use information about how you use and connect to the Website, App or Services to present the Website, App or Services to you on your device. | The processing is necessary for our legitimate interests, namely to provide the Website, App or Services to the user. |
| We use this information to monitor and detect fraud or suspicious activity on our Website, App and Services. | The processing is necessary for our legitimate interests, namely monitoring fraud. |
| We use this information to monitor the performance of the Website, App and Services to identify errors and ways in which we can improve the Website, App and Services, including developing new features of the Website, App and Services. | We will only use your personal data in this way to the extent you have given us your consent to do so. |
| We use this information to monitor the performance of the Website, App and Services to identify errors and ways in which we can improve the Website, App and Services, including developing new features of the Website, App and Services. | We will only use your personal data in this way to the extent you have given us your consent to do so. |
| How we use it | Lawful basis we rely on |
|---|---|
| We use information about how you use and connect to the Website, App or Services to present the Website, App or Services to you on your device. | The processing is necessary for our legitimate interests, namely to provide the Website, App or Services to the user. |
| We use this information to monitor and detect fraud or suspicious activity on our Website, App and Services. | The processing is necessary for our legitimate interests, namely monitoring fraud. |
| We use this information to monitor the performance of the Website, App and Services to identify errors and ways in which we can improve the Website, App and Services, including developing new features of the Website, App and Services. | We will only use your personal data in this way to the extent you have given us your consent to do so. |
| We use this information to monitor the performance of the Website, App and Services to identify errors and ways in which we can improve the Website, App and Services, including developing new features of the Website, App and Services. | We will only use your personal data in this way to the extent you have given us your consent to do so. |
We may link or combine the personal data you provide and the information we collect automatically. This allows us to provide you with a personalised experience regardless of how you interact with us.
We may anonymise and aggregate any of the personal data we collect (so that it does not directly identify you), and may use the anonymised and aggregated information or disclose it as set out in our Privacy Policy.
Our Website, App and Services use cookies and similar technologies such as pixels and Local Storage Objects (LSOs) like HTML5 (together “cookies”) to distinguish you from other users of our Website, App, and Services. This helps us to provide you with a good experience when you browse our Website, App, or Services and also allows us to monitor and analyse how you use and interact with our Website, App, or Services so that we can continue to improve our Website, App, and Services. It also helps us determine products and services that may be of interest to you. Please see our Cookie Policy for more information about these practices and your choices regarding cookies.
We will usually store the personal data we collect about you for no longer than the following:
| Category of personal data | How long we keep it |
|---|---|
| Your contact details |
If you are a prospective customer, we will keep your contact details for 3 years from the last contact we had with you (such as the last email we sent you or the last time you contacted us). If you are a customer admin user, we will keep your contact details for the duration of our agreement with the customer and for 6 years thereafter. |
| Queries and comments you submit to us |
If you are a prospective customer, we will keep the content of any correspondence from you for 3 years from the last contact we had with you (such as the last email we sent you or the last time you contacted us). If you are a customer user, we will keep the correspondence you send us for the duration of our agreement with the customer and for 6 years thereafter. |
| Password information | If you are the customer, we will store your password for the duration of our agreement with you. If you change or reset your password, we will delete your previous password and only store the new password. |
| Marketing preferences |
If you are a prospective customer, we will keep your contact details for 3 years from the last contact we had with you (such as the last email we sent you or the last time you contacted us). If you are a customer admin user, we will keep your marketing preferences for as long as you are designated a customer admin and for 3 years thereafter. |
| Information about your device and how you use the Website, App and Services | We will keep this information for no longer than 3 years. |
We may share your personal data as follows:
| Recipients | Why we share your personal data with these recipients | How these recipients will use your personal data |
|---|---|---|
| Service providers |
We will share your personal data with companies that provide services to us, such as:
|
These recipients will use your personal data as processors on our instructions. |
| Advertising partners | We may share your personal data with our advertising partners as further described in the “online advertising” section below. |
These recipients will process personal data to optimise the advertising shown on our Website, App and Services, measure the effectiveness of such advertising and serve advertising about CircleCo on other websites that you visit. We will only share your personal data in this way to the extent you have given us your consent to do so. |
| Buyers of our business | We may share personal data with other parties in connection with a transaction or potential transaction where we merge with another organisation, file for bankruptcy, or sell some or all of our assets or stock. For instance, if we sell the Website, App or Services to a third party, we will share the personal data we have collected through the Site with that buyer. |
These recipients will use your personal data to complete a transaction to buy all or the part of our business that includes the Website, App or Services. The lawful basis rely on for sharing personal data with these recipients is that it is necessary for our and the recipient's legitimate interests, namely completing a transaction to buy all or part of our business. |
| Law enforcement, regulators and other parties for legal reasons | We may share your personal data with third parties as required by law or if we reasonably believe that such action is necessary to (i) comply with the law and the reasonable requests of law enforcement; (ii) detect and investigate illegal activities and breaches of agreements; and/or (iii) exercise or protect the rights, property, or personal safety of CircleCo, its users or others. | These recipients will use your personal data in the performance of their regulatory or law enforcement role. The lawful basis we rely on for sharing personal data with these recipients is that the processing is either necessary to comply with a legal obligation to which we are subject, or is necessary for our legitimate interests, namely enforcing our rights or complying with requests from regulatory authorities. |
From time to time we may contact you with information about our products and services, including sending you marketing messages and asking for your feedback on our products and services.
For some marketing messages, we may use personal data we collect about you to help us determine the most relevant marketing information to share with you.
We will only send you marketing messages if you have given us your consent to do so. You can withdraw your consent at a later date by clicking on the “unsubscribe” link at the bottom of our marketing emails or by updating your preferences via the App settings.
We work with online advertising networks and advertising partners to tailor the ads played or displayed to you on our Website, App and Services and on other websites, apps, or services. The ads you see online are tailored to your interests based on information collected about you, including information about your age, demographic, location, as well information about your internet usage over time, such as the websites you visit, the products and pages you view and the links you click on (including links in ads played or displayed to you).
Typically, this information is collected through cookies or similar tracking technologies. When you visit the Website, App or Services we will, if you give us your consent to do so, place cookies and similar tracking technologies on your device to:
Please see our Cookie Policy for details of the third parties that collect information about your use of the Website, App and Services for advertising purposes.
We will only collect and share information about your use of the Website, App and Services for advertising purposes to the extent you have given us your consent to do so.
Withholding or withdrawing consent, or opting out of the use of advertising cookies, will mean that information about your use of the Website, App and Services will not be shared with advertising networks to allow us to target advertising on other websites.
If you opt-out of advertising by opting out of the use of, or withholding or withdrawing your consent to advertising cookies, you will still get ads when you browse the internet, and those ads may still be relevant to your interests. However, this advertising may be based on the content of the site you visit or, for advertising on social media, your approximate location or demographic information associated with your social media profile, rather than your recent browsing activity. As a result, you may still see advertising relevant to your location, demographic or other information on the websites you visit even if you reject cookies on the Website, App or Services.
Security. We implement appropriate technical and organisational measures to protect your personal data against accidental or unlawful destruction, loss, change or damage. We will never send you unsolicited emails or contact you by phone requesting your account ID, password, credit or debit card information or national identification numbers.
International Transfers of Your Personal Data. The personal data we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations, including in the United States.
In the event of such a transfer, we ensure that: (i) the personal data is transferred to countries recognised as offering an equivalent level of protection (“Adequacy”); or (ii) the transfer is made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission or approved under the UK Data Protection Act 2018 (“Standard Contractual Clauses”). When we transfer your personal data to recipients in the United States, we ensure that such transfers are:
In accordance with applicable privacy law, you have the following rights in respect of your personal data that we hold:
Right of access. You have the right to obtain.
We may update this European Privacy Policy from time to time and so you should review this page periodically. When we change this European Privacy Policy in a material way, we will update the “Effective Date“ above. Changes to this European Privacy Policy are effective when they are posted on this page.