This United States Regional Privacy Notice (“Notice”) is for people living in the United States and supplements our Circles Privacy Policy, which explains how we collect, use, and disclose your Personal Information. 

This U.S. State Privacy Rights Notice describes how to exercise your rights under the Colorado Privacy Act, the Connecticut Act Concerning Personal Data Privacy and Online Monitoring, the Utah Consumer Privacy Act, the Virginia Consumer Data Protection Act, the Oregon Consumer Privacy Act, the Texas Data Privacy and Security Act, and the Montana Consumer Data Privacy Act. We call those laws collectively the “U.S. Privacy Laws.” For California Privacy Rights, please refer to the California Notice at Collection.

When we say “Personal Information” in this Notice, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked with you, directly or indirectly. Personal Information does not include information that cannot be reasonably linked to you. When data is deidentified (as defined under the U.S. Privacy Laws), we maintain it in deidentified form and do not attempt to reidentify the information.

U.S. State Privacy Rights

If you are a resident of a state that has laws that govern our processing of your Personal Information, you may have certain rights, as provided under the state law applicable to you, subject to certain exemptions, which may include the:

• Right to Know (All Listed States): The right to request that we disclose to you the Personal Information that we collected or disclosed about you including:
  • The categories and specific pieces of Personal Information we have collected about you;
  • The categories of the sources of the Personal Information;
  • The purposes for which your Personal Information is collected and used;
  • The categories of Personal Information that the business disclosed for a business purpose, and for each category identified, the categories of third parties to whom that particular category of Personal Information was disclosed; and
  • The categories of Personal Information that the business sold or shared, and for each category identified, the categories of third parties to whom that particular category of Personal Information was sold or shared;
• Right to Access/Data Portability (All Listed States): Access, request and receive, up to twice every 12 months, a portable copy of the Personal Information that we have collected about you in the last 12 months;
• Right to Correct (All Listed States Except Utah): The right to request that we correct inaccuracies in your Personal Information that we maintain about you;
• Right to Request Deletion (All Listed States): The right to request that we delete or erase  Personal Information we have collected about you, subject to certain exemptions;
• Right to Limit the Use and Disclosure of Sensitive Personal Information (CA): The right to direct us to limit our use of your sensitive Personal Information to that use which is necessary to perform the services or provide the goods as reasonably expected by someone who requests those goods or services and for business purposes allowed by law;
• Right to Opt-In for Sensitive Data Processing (CO, CT, MT, OR, TX and VA): The right to opt-in for the use of sensitive Personal Information, which may include race, ethnicity, precise geolocation data, minor information and certain health data.
• Right to Opt-Out (Applicability Varies by State): The right to opt-out of or object to having your Personal Information sold to, or shared with, third parties for the purposes of targeted advertising or to process your personal data for profiling in furtherance of decisions that produce legal or similarly significant effects on you; and
• Right to Non-Discrimination (All Listed States): The right not be discriminated against by us for exercising any of these rights.
• Right to Appeal (All Listed States): The right to submit an appeal if your request is denied.

Exercising Your Rights

You or your authorized agent may submit a request to exercise your rights by visiting hello@circlesup.com or calling us at (+1)4075641770 (Monday through Friday, 8:30 AM – 9:00 PM Eastern). For your security and to ensure unauthorized third parties do not access your Personal Information, we will require you to verify your identity before we can act on your request. If you are a current customer or still have access to your Circles account, you will be required to authenticate through your Circles account. If you do not have an account with us, you will be required to provide an email address and mobile phone number to start the verification process. You may also be required to provide a qualified government-issued photo identification. If you are asking for access on behalf of someone else, we will require verification of your identity, as well as proof of authorization by the individual whose Personal Information you wish to access.

Authorized Agents

If you are a resident of a state that has laws that govern our processing of your Personal Information and would like to designate an authorized agent to submit certain requests on your behalf, or if you are an authorized agent of an individual with the right to submit certain requests via an authorized agent and would like to submit a request on behalf of that individual, please send an email to the following email address: hello@circlesup.com. If you are the resident, in order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such request. We may also follow up with you to verify your identity before processing the authorized agent’s request. If you are the authorized agent, after you submit the request, and if the request is not subject to an exemption or exception, we will require additional information to verify the identity of the resident, as well as your authority to act on behalf of the resident.

Appeals

If we did not take action on your request, and if you are a resident of a state that offers a right to an appeal, you may have the right to appeal our decision. To submit an appeal, hello@circlesup.com. Please note that an appeal must be submitted within 60 days of your receipt of the notice not to take action.

Contact Us 

If you have additional questions about this Notice or how to exercise your rights under applicable U.S. Privacy Laws, please contact us at: hello@circlesup.com.