Introduction
Circle Systems along with its various affiliated businesses (collectively, “Circle Systems”, “we”, “us” or “our”) wants to inform you about the ways in which we process your personal information. In this Cookie Policy, we explain what personal information we collect, use, and disclose.
Personal information means any data relating to an individual based on which they can be identified, directly or indirectly. This may include information such as names, contact details, (online) identification data, online identifiers, or other characteristics specific to that individual.
This Cookie Policy is applicable when you visit our websites, solutions, and applications. This Cookie Policy may be supplemented or replaced by additional privacy statements or terms provided to you from time to time.
Who are we?
Circle Security, is a Silicon Valley start-up, offering its prevention-first cybersecurity platform. With early funding from strategic investors, Circle Security has built a patented technology that transforms how companies access and protect data by overcoming the most pervasive cybersecurity challenges faced by them in today’s dynamic world.
What personal information do we collect?
We may collect the following personal information about you:
- Financial Information, such as bank account, credit card, and debit card numbers for processing payments
- User web activity, such as behavioral information about how you navigate within our products, which features you use the most, and information regarding the goods and/or services you wish to order, wish list, preferences, interests, etc. Other information shared by you through our websites, apps, and other products.
- Computer, device, and connection information, such as IP address, browser type, version, and location.
- Any other information shared by you through our websites and apps.
How we collect the personal information
Personal information is used for the purposes for which it has been collected and might be further used for statutory or other legitimate purposes only. As an example, if you use our contact form on our website, we will use the information you provided in the first place to respond to your request. We might further use that information to improve the quality of our customer service process.
Lawfulness of the processing is one of the main principles relating your personal information - we apply the following legal processing grounds:
- Processing is necessary for the performance of a contract, or in order to take steps prior to entering into a contract.
- Processing is necessary for the purposes of our legitimate interests - for example, to improve the quality of our products and the implementation of customizations.
- Processing is necessary to comply with a legal obligation to which we are subject, or otherwise lawful under the applicable data protection laws.
- With your given consent.
Depending on how you interact with us and our website, we may use your personal information for the following purposes:
- Administering the relationship between you and our business, such as frequency of use and currently active users.
- Improving our product and feature offering by inviting you to participate in surveys or analyzing website traffic to optimize our websites or to personalize your experience.
- Marketing, such as customer segmentation, to provide you with marketing or advertising communications that we think you may be interested in. This processing is with your given consent or for our legitimate interests.
- Other general business support purposes, including but not limited to procurement, financial and fiscal management, risk and compliance management. This processing is necessary for compliance with a legal obligation to which we are subject, or that is otherwise lawful under the applicable data protection laws, or for our legitimate interests.
Sharing your personal information
To be able to provide you with the best customer experience, we may share certain information internally or with selected third parties. There might also be a certain statutory or legal obligation that we believe in good faith requires us to disclose your personal information externally. Parties we might share data with include:
- Other Circle System affiliates or subsidiaries, e.g., for customer data management or providing underpinning technology to support the products that we are delivering.
- Our business partners, to the extent you have purchased or expressed interest in a product or service of such a business partner, interacted with them, or otherwise authorized the sharing of your personal information with such a business partner.
- Subscribing, accrediting or professional organizations, e.g., for providing utilization information to organizations that provide you with access to our products and/or sharing tracking and redeeming credits for professional accreditation.
- Organizations involved in business transfers, e.g. to a purchaser or successor entity in the event of a sale or any other corporate transaction involving some or all of our business.
- Other parties, e.g. as needed for external audits, compliance, risk management, corporate development, and/or corporate governance-related matters; or
- Governmental authorities and regulators, as required under the applicable law.
Whenever we share personal information internally or with third parties in other countries, we have appropriate safeguards in place in accordance with the applicable data protection laws, including as applicable the EU Model clauses. As required under the applicable law, third parties are required to use appropriate safeguards to protect personal information, and they can only access the personal information that is necessary for performing their specific tasks.
How long do we keep your personal information
We have put in place an internal framework of policies and minimum standards across all our businesses to keep your data safe. In addition, we limit access to personal information by our employees, business partners, service providers, and third-party service providers to a ‘need-to-know’ basis. More specifically and in accordance with the law, we take appropriate technical and organizational measures (policies and procedures, IT security, and others) to ensure the confidentiality and integrity of your personal information and the way it is processed.
What are your rights?
As a global organization, we operate in different jurisdictions which grant individuals different levels of protection in relation to the processing of personal information. We will honor your rights under the applicable law. To the extent provided under your local data protection laws, including the European data protection laws as applicable, your rights may include the following:
- Right of access (‘an overview of your personal information’): The right to get an overview of your personal information that we process.
- Right to rectification (‘correct your personal information’): If your personal information is inaccurate or incomplete, the right to ask us to rectify or complete your personal information.
- Right to erasure (‘right to be forgotten’): The right to request that we delete your personal information to the extent permitted by the applicable law. In certain circumstances, it may not be possible for us to accept your request; for example, when the processing is necessary to comply with a legal obligation, or if the processing is necessary for the performance of a contract.
- Right to data portability (‘transfer your personal information’): The right to ask us to transfer your personal information directly to you. This applies to certain personal information if processed by automated means and with your consent, or based on a contract you have with us. On your request, and where technically feasible, we will transfer your personal information to another party of your choice.
- Right to restrict processing: The right to request that we restrict or stop the processing of your personal information held by us for a certain period of time, or for an indefinite period. In certain circumstances, it may not be possible for us to accept your request; for example, when the processing is necessary to comply with a legal obligation, or if we can demonstrate compelling legitimate grounds otherwise.
- Right to object: The right to object to the processing of your personal information. The reasons for an objection should relate to your particular situation and be related to processing based on the legitimate interest condition. We will no longer process the personal information unless we can demonstrate compelling reasons otherwise. In certain circumstances, you have the unconditional right to object, for instance, in the context of direct marketing activities.
- Withdrawal of Consent: The right to withdraw your consent to the processing of your personal information at any time; for instance, after you consented to us keeping you informed about our products, you have the right to withdraw this consent at any time. Withdrawal of your consent will not affect the lawfulness of the processing of your personal data prior to the withdrawal.
To exercise your rights (if applicable) and/or for any other questions about the handling of your personal information, feel free to raise an inquiry on ‘CONTACT US‘.
If you feel we are unresponsive or disagree with our data privacy practices, you can also file a complaint with your local Data Protection Authority.
The use of cookies
We use cookies to optimize our websites and analyze website traffic. On occasion, if we have obtained your informed consent in advance, we may use third-party cookies, notably social media plugins, to enable you to share ideas and information related to us instantly and for our own marketing purposes.
Cookies or similar techniques (referred to collectively as “Cookies”) are small text files or pixels, which might be stored on your computer or mobile device. Cookies may be necessary to facilitate website browsing and make it more user-friendly. Cookies may also collect information to analyze personal browsing behavior.
We may use Cookies belonging to one of the four categories listed below.
- Strictly Necessary Cookies - These cookies are necessary for the website to function. They are usually set in response to actions made by you that amount to a request for services, such as setting your privacy preferences, logging in, or filling in forms. You can set your browser to block or alert you about these cookies, this may have an effect on the proper functioning of (parts of) the site.
- Functional Cookies - These cookies enable the website to provide enhanced functionality, user experience, and personalization, and may be set by us or by third-party providers whose services we have added to our pages. If you do not allow these cookies, then some or all of these services may not function properly.
- Performance Cookies - These Cookies support analytic services that help us to improve our website’s functionality and user experience.
- Advertising Cookies - These Cookies can be applied to collect insights, issue personalized content, and advertise on our own and other websites.
Link to other websites
Our websites may contain links to other third-party websites or marketplaces, which may have their own Cookie Policy that differs from ours. We are not responsible for the collection, processing, or disclosure of personal information collected through such other websites.
We are also not responsible for any information or content contained on such websites. Links to other websites are provided solely for convenience. Your usage and browsing on any such website are subject to that website’s own policies. Please review the cookie policies posted on other websites that you may access through our website.
Circle Systems may provide you with additional or different policies, in specific instances, on how your personal information is collected and used for specific a product.
How to contact us
If you have any questions about how we process your personal information or if you want to exercise one of your rights, you can contact us by using this inquiry link ‘CONTACT US’.
If you feel we are unresponsive or disagree with our data privacy practices, you also have a right, depending on applicable law, to file a complaint with your local Data Protection Authority.
In response to a request, we might ask you to verify your identity if needed, and to provide information that helps us to understand your request better. If we do not grant your request, whether in whole or in part, we will explain why.
Updates to this Policy
From time to time, we may update this Cookie Policy or any other specific privacy statement. When making changes to this Cookie Policy, we will add a new date to this Policy. This version is effective as of March 2023. Please see our Web Site Privacy Policy for more details.
