Privacy & Cookies Policy

Circleze operates this website. Circleze (also referred to as “we” and “us”) may collect personal information about you through your use of this website. This Privacy Notice describes how we collect and use your personal information and the rights you have concerning that information.

As a business, we are committed to respecting and protecting the privacy of all individuals with whom we interact. We will process your personal information at all times following applicable privacy and data protection laws. Besides, we participate in the European Digital Alliance (EDAA) self-regulatory programme and adhere to the EDAA Principles for Online Behavioural Advertising.

This Privacy Notice explains the following:

  • What personal information we collect on this website
  • How we use this information
  • How we store your personal information
  • How we secure your personal information
  • Whether we disclose or share your personal information
  • Your rights regarding the personal information you provide to us
  • Our responsibility for website links
  • How to contact us

In the Supplementary Information section of this Privacy Notice, we explain what is meant by “personal information” and other terms used in this notice.

The Personal Information we collect on this website

We collect information about how you use our website and the device(s) you use to access our site. This includes collecting unique mobile device ID, or the internet protocol (IP) address online identifiers, which are numbers that can uniquely identify a specific computer or another network device on the internet. This information is linked to a cookie ID, which we receive and process. You may find more information on our use of cookies on our separate Cookies Notice.

We also collect personal information about you if you make use of any of the interactive features within our website. For example, when you complete data capture forms on our site, or when you respond to a blog on our website. We do not collect sensitive information, such as your political or religious beliefs, ethnic background, sexual preference, health or any other confidential information.

We do not actively seek to collect information about children aged 16 or under. If you have any concerns about your child’s privacy concerning our services, or if you believe that your child may have shared personal information via this website, please contact us at privacy@circleze.com. We will delete such information from our records at a reasonable time.

How we use this information

Except where required by law, we only use the personal information you provide for the following purposes:

To deliver the specific information or service you have requested. For example, if you have subscribed to our newsletter or submit an enquiry concerning a job or career opportunity through this site, we will only use the email address you provide to us to respond to that request. Without your express consent, we will not use your contact details for any other purpose.

We ensure that we always have an appropriate legal basis for processing your personal information. For the most part, the processing of your personal information is based on either a) our legitimate interests related to us providing you services you have requested or otherwise your customer relationship with us, or b) your consent, where requested.

How we store your personal information

We are committed to ensuring your personal information is kept secure and confidential and not stayed for longer than is necessary for the purposes they were processed. When your personal information is no longer required, it will be deleted.

From time to time we may ask other members of our group, or third party service providers, to help us manage the information technology systems that are used to process your personal information. Some of these systems may be located in countries overseas, including countries located outside the European Economic Area (EEA) where the level of data protection has not been deemed sufficient by the European Commission.

We will only transfer your information to a third party service provider or overseas, where we are satisfied that adequate levels of protection are in place to protect the integrity and security of any information being processed and compliance with applicable privacy and data protection laws. These measures may include the use of Standard Contractual Clauses, the EU-US Privacy Shield, Swiss-US Privacy Shield or your consent. You may request further information on the legal security measures used for such transfers via the contact details given in this Privacy Notice.

How we secure your personal information

We have appropriate security measures in place to prevent unlawful or unauthorised use, access or accidental loss of personal information. We also seek to ensure that our service providers do the same.

Information Sharing and Disclosure
We do not sell or rent any personally identifiable information about you to any third party.

We may disclose personally identifiable information in response to legal process, for example in response to a court order or a subpoena, or reply to a law enforcement agency’s request, or where we believe it is necessary to investigate, prevent or take action regarding illegal activities, and as otherwise required by law.

We may be required to share your personal information with other members of the Circleze or other third parties who provide services to us. This may entail the transfer of your personal information to countries outside the EEA. However, we only transfer your personal information to a third party service provider or overseas, where we are satisfied that adequate levels of protection are in place to protect the integrity and security of any information being processed and compliance with applicable privacy and data protection laws.

Your rights regarding the personal information you provide to us

General rights
If you wish to stop receiving marketing communications from us, then please click on the “unsubscribe” link at the bottom of the relevant mailing. If you want to opt-out completely, then please contact us at using the details provided below.
If you would like us to delete your information from our records, please contact us using the contact details below, and we will respond within a reasonable time. Please note that we may be required to retain specific information by law and/or for our own legitimate business purpose.
Users from the European Economic Area

If you are from the European Economic Area, you have rights (with some exceptions and restrictions) to:

  • Object to our processing of your personal information, including profiling. You can object at any time, and we shall stop processing the information you have opposed to unless we can show compelling legitimate grounds to continue that processing;
  • Access your personal information. If you make this kind of request and we hold personal information about you, we are required to provide you with information on it, including a description and copy of the personal information and why we are processing it;
  • request erasure of your personal information in certain circumstances;
  • request correction or updating of the personal information that we hold about you and that is inaccurate;
  • Request the restriction of our processing of your personal information in some situations. If you request this, we can continue to store your personal information but are restricted from further processing it while the restriction is in place;
  • Where our handling of your personal information is based on your consent, you may withdraw your consent at any time. Withdrawing your consent does not affect the lawfulness of what we had done with your personal information before you withdrew consent;
  • Complain to your local data protection authority about our collection or use of your personal information. For example, in the UK, the local data protection authority is the UK Information Commissioner’s Office.

If you exercise the rights above and there is any question about who you are, we may require you to provide information from which we can satisfy ourselves as to your identity.

If you are from the European Economic Area and would like to exercise any of these rights concerning the personal information we hold about you via this website, please contact us using the contact details provided below. We will consider and respond to your request following the relevant law.

Our responsibility for website links

This Privacy Notice is limited to the personal information which we collect and use via this website. We provide links within this site to other websites, including social media sites such as Facebook, Twitter, LinkedIn and Instagram sites operated by Circleze. If you follow these links, you should use these sites in conjunction with their applicable user and privacy notices as their data practices fall outside the scope of this Privacy Notice. Further, we can have no responsibility for or control over the information collected by any third party website, and we cannot be responsible for the protection and privacy of any information which you may provide on such websites.

Updates

This Privacy Notice may be updated from time to time to reflect changes in law, best practice or a change in our practices regarding the treatment of personal information. If you do not agree to the changes, please do not continue to use our website. You should check this notice frequently for updates. This notice was last updated on 25 March 2019.

Contact us

If you have any questions about our approach to privacy or you would like to exercise any of the rights mentioned in this Privacy Notice you can contact us directly below.

Email: privacy@circleze.com

SUPPLEMENTARY INFORMATION

In this Supplementary Information section, we explain some of the terminology used in this Privacy Notice.

personal information” – any information that relates to you (or from which you can be identified).

profiling” – automatically using personal information to work out certain things about people, like analysing or predicting their performance at work, reliability, economic situation, personal preferences, interests, behaviour, location or movements.

Cookies Notice

How we deploy “cookies”

Cookies are small packets of information stored by your web browser when you visit certain websites, including our website. Cookies are generally used by sites to improve your user experience by enabling that website to ‘remember’ you, either strictly for the duration of your visit (using a “Session” cookie which is erased when you close your browser) or for repeat visits (using a “Permanent” cookie).

We do not use cookies to store any personally identifiable information about you. However, please be advised that in some countries data such as cookie IDs and IP-/MAC- addresses are considered to be personal information. To the extent we process such data that is regarded as personal information, this will be done following our Privacy Notice.

Our site uses the following types of cookies:

Strictly necessary cookies

These cookies are essential to enable you to move around the site and use its features. These are known as “First Party” cookies. Without these cookies, services like allowing appropriate content based on your type of device cannot be provided.

– Cookie’s name and purpose:

Google Tag Manager – GTM
Helps make tag management simple, easy and reliable by us to deploy website tags all in one place. In this case, tags are most often JavaScript and non-JavaScript code.

Performance cookies

These cookies provide information about how visitors use the site so that we can analyse traffic and understand how our visitors use our website. We use cookies issued by a third party, Google Analytics, for this purpose (“Third Party” cookies). Google Analytics uses its cookies. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how the site works. You can find out more about Google Analytics cookies here:

https://developers.google.com/analytics/resources/concepts/gaConceptsCookies

You can avoid the use of Google Analytics relating to your use of our site by downloading and installing the Browser Plugin available via this link:

http://tools.google.com/dlpage/gaoptout?hl=en-GB

– Cookie’s name and purpose:

Analytics – Google Universal – Event
Web analytics service offered by Google that tracks and reports website traffic.

Analytics – Google Universal – Non-interactive event
Web analytics service offered by Google that tracks and reports website traffic.

Analytics – Google Universal – Pageview
Web analytics service offered by Google that tracks and reports website traffic.

Analytics – Google Universal – Virtual Form Completed
Web analytics service offered by Google that tracks and reports website traffic.

Google Analytics Audiences
Collects and organizes site data sources.

Yahoo Analytics
Web analytics service offered by Yahoo that tracks and reports website traffic.

Functionality cookies

If we process personal data in a third country (i.e. outside the European Union (EU) or the European Economic Area (EEA)) or if this occurs in the context of the use of third-party services or disclosure and/or transfer of personal data to third parties, we shall only transfer personal data to comply with our (pre)contractual obligations, based on your consent, a legal obligation or our legitimate interests. Subject to legal or contractual authorisations, we process or have personal data processed in a third country only where the particular conditions of Art. 44 et seq GDPR are met. This means, for example, that processing and the transfer is carried out on the basis of special safeguards, such as the officially recognised setting of level of data protection corresponding to the EU (e.g. for the USA by the “Privacy Shield”) or compliance with officially recognised special contractual obligations (known as “standard contractual clauses”).

For how long are personal data stored and processed?

These cookies allow our site to remember choices you make (such as the region you are in) and provide enhanced, more personal features. These cookies will also be used to recognise changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised, and they cannot track your browsing activity on other websites.

Social Media Cookies

These cookies are used when you share information using a social media sharing button, or you link your account or engage with our content on or through a social networking site such as Facebook, Twitter, LinkedIn or Instagram. The social network will record that you have done this. This information may be linking to targeting/ advertising activities.

– Cookie’s name and purpose:

Facebook Connect
Allows users to interact on other websites through their Facebook account.

How to reject cookies

If you don’t want to receive cookies, you can alter your browser settings. The procedure for doing so varies from one browser application to another. If you wish to reject cookies from our site but want to accept those from other sites, you may choose the option in your browser settings to receive a notice before a cookie stored on your device. Please consult the “Help” section of your browser for more information. 
To find out more about cookies, please visit the relevant website set out next to your country of origin below:

United Kingdom
Your Online Choices: www.youronlinechoices.com/uk

Other European Countries
Your Online Choices: www.youronlinechoices.com

Any
All About Cookies: www.allaboutcookies.org

Please note that by disabling cookies, you may prevent from accessing some features of our site or specific content or functionality may not be available.

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