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Unless otherwise defined in this California Privacy Notice (this “Notice”), all terms defined in the Privacy Policy and all other terms defined in the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (“CCPA”) retain the same meaning when used in this Notice.
This Notice supplements the information contained in our Privacy Policy applies solely to individual residents of the State of California (“consumers” or “you”).
This Notice describes how we collect, use, disclose and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the CCPA.
When we use the term “personal information” in this Notice, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household in accordance with the CCPA.
For the purposes of this Notice, personal information does not include:
As described further in the “How We Share Your Personal Information” section of the Privacy Policy, we share personal information internally and with our service providers and contractors that help us operate our Platform and business. We may also share personal information with a variety of third parties, including for marketing purposes; if we are subject to certain corporate transactions or reorganizations; with third parties to comply with law or to protect our rights or the rights and safety of others; or for purposes otherwise disclosed or for which you have consented.
For purposes of this Notice, when we use the term “third party” we mean entities that are not service providers or contractors providing services on behalf of Circles and that are not entities with whom you interact with directly.
In the last 12 months, we have collected each of the categories of personal information noted in the table below and disclosed it, for a business purpose, to the categories of recipients listed below. The table also indicates when we shared or sold the personal information to third parties in the last 12 months and the types of third parties.
| Category of Personal Information | Categories of Recipients to Whom Personal Information Is Disclosed for Business Purposes | Sold or Shared with Third Parties | Categories of Third Parties to Whom Personal Information Is Sold or Shared |
|---|---|---|---|
| Identifiers, such as name, email address and other information. | Service Providers & Business Partners | Yes | Business Partners, Data Analytics Partners & Social Media Networks |
| California Customer Records (Cal. Civ. Code § 1798.80(e)), such as birthdate and Payment Information. | Service Providers & Business Partners | Yes | Business Partners, Data Analytics Partners & Social Media Networks |
| Protected Classification Characteristics, such as age, ethnicity and gender. | Service Providers & Business Partners | Yes | Business Partners |
| Commercial Information, such as Shopping History and other information relating to your hobbies, interests and shopping behavior. | Service Providers & Business Partners | Yes | Social Media Networks, Business Partners, Data Analytics Partners, Marketing Partners, Review Platforms & Online Advertising Networks |
| Biometric Information, such as behavioral characteristics used to identify you; imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, voice recordings, etc. | Not Applicable | No | None |
| Internet/Network Information, such as IP address, Device Information, and Log and Analytics Data. | Service Providers & Business Partners | Yes | Business Partners, Social Media Networks, Data Analytics Partners, Customer Service Providers & Online Advertising Networks |
| Geolocation Data, such as Location Information from your device or estimated based on your IP address. | Service Providers & Business Partners | Yes | Business Partners, Social Media Networks, Data Analytics Partners & Online Advertising Networks |
| Sensory Information, such as audio, electric, visual, thermal, olfactory, call and session recordings, or similar information. | Service Providers | Yes | Service Providers |
| Other Personal Information, such as information you post on our Platform or on social media pages, and information you submit to us. | Service Providers | Yes | Review Platforms |
| Inferences, such as predictions about your interests and preferences. | Service Providers & Business Partners | Yes | Business Partners, Data Analytics Partners, Social Media Networks & Online Advertising Networks |
| Sensitive Personal Information, such as: account log‐in credentials; precise geolocation; racial or ethnic origin, religious or philosophical beliefs; etc. | Service Providers & Business Partners | Yes | Business Partners |
We do not use or disclose Sensitive Personal Information outside of the permitted purposes set forth under Section 7027(m) of the California Consumer Privacy Act Regulations.
As described in the “How We Collect Your Personal Information” section of the Privacy Policy, we collect personal information directly from you when you provide it to us, automatically using cookies and other tracking technologies, from the categories of third parties listed in that section and by combining personal information we may otherwise obtain.
We collect, sell, share or disclose personal information about you for the business and commercial purposes further described in the “How We Use Your Personal Information” section of the Privacy Policy.
The period for which we retain your personal information varies, depending on the type of personal information and the purpose for which it was collected. The duration is limited to time necessary to fulfill the purposes for which the information was collected, in light of any restrictions or deletions you might request, as well as our need to address our legal obligations or rights.
As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations at law):
| Right to Know |
The right to request the following information relating to the personal information we have collected about you and disclosed about you:
|
| Right to Access (Right to Know Specific Pieces of Information) / Portability | The right to access and obtain a copy of the specific pieces of Personal Information we have collected about you in a structured, machine-readable format that may be transmitted to another entity without hindrance, to the extent technically feasible. |
| Right to Correct | The right to request that we correct your inaccurate personal information maintained by us. |
| Right to Request Deletion | The right to request the deletion or erasure of personal information we have collected from you, subject to certain exceptions. |
| Right to Opt Out of Data Sales or Sharing | The right to direct us not to sell or share personal information we have collected about you to third parties, including for ad targeting/cross contextual advertising. |
| California’s “Shine the Light” Law | California’s “Shine the Light” law (Civil Code § 1798.83) also permits California residents that have an established business relationship with us to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year or to have the right to opt-out of such disclosures. |
To Exercise Your Rights to Know, Access, Correct, Delete and/or “Shine the Light”
Please submit a request by contacting us at: hello@circlesup.com.
We may need to verify your identity and confirm you are a resident of the State of California before processing most requests, which may require us to obtain additional personal information from you. In order to verify your identity, we will generally require either the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. Please provide your name, email address and mailing address in the original request, as well as an explanation of the rights you wish to exercise. We will only use the personal information provided in connection with a Privacy Rights Request to review and comply with the request. If you do not provide this information, we may not be able to verify or complete your request in all circumstances.
If you wish to submit a verifiable consumer request on behalf of another individual we will also need sufficient information to verify that the individual is the person about whom we collected personal information and that you are authorized to submit the request on their behalf. Please see the “Authorized Agents” section below for more information.
In certain circumstances, we may decline a request to exercise the rights described above, in accordance with applicable law.
You do not need to create an account with us to exercise your Right to Opt Out of Personal Information Sales or Sharing. However, we may ask you to provide additional personal information (including your name, email address and mailing address) so that we can properly identify you in our dataset to facilitate the opt-out request. If you choose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems.
Once you make an opt-out request, you may change your mind and opt back in to personal information sales or shares at any time by contacting us at hello@circlesup.com.
To exercise your right to opt-out of personal information sales or sharing, please submit a request by contacting us at: hello@circlesup.com.
In addition, as is common practice among companies that operate online, we permit third party advertising networks, social media companies and other third party businesses to collect personal information directly from your browser or device through cookies or similar online tracking technologies when you visit or interact with our websites, use our apps or otherwise engage with us. For example, they may collect Internet/Network information, such as a cookie or device ID, browsing history and website usage, Geolocation Data, Commercial Information, and Inferences generated from your browsing history and interactions with our service as well as other sites and services. These third parties use this information for the purposes of serving ads that are more relevant, for ad campaign measurement and analytics, and for fraud detection and reporting and may sell or share that information to other businesses for advertising and other purposes. You can request that your information not be sold or shared by contacting us at: by contacting us at hello@circlesup.com. Please see the section entitled “Online Advertising and Third Party Tracking” in our Privacy Policy to learn how you may exercise your choice over this data collection for advertising purposes.
We do not sell or share personal information of consumers we know to be less than 13 years of age unless we receive affirmative authorization from the parent or guardian of a child less than 13 years of age. The parent who has opted into personal information sales or sharing may opt out at any time. If a parent, guardian or child has provided affirmative authorization, they may opt out of future processing at any time by contacting us at hello@circlesup.com.
In certain circumstances, you are permitted to use an “authorized agent” (as that term is defined by the CCPA) to submit CCPA requests on your behalf. We may verify the authorized agent’s authority to act on your behalf as follows:
For requests to know, access, correct or delete personal information, we may ask you to provide sufficient evidence to show that you have provided the authorized agent signed permission to act on your behalf, verified your own identity directly with us pursuant to the instructions set forth in this Notice, and directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.
For requests to opt-out of personal information “sales” or “sharing,” we may ask you to provide a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.
We do not discriminate against you for requesting any of the rights noted above. We are permitted to deny or limit your request in accordance with applicable laws.
If you have any questions, comments or concerns with respect to our privacy practices or this Notice, or wish to update your information, please feel free to contact us at hello@circlesup.com. or by telephone at (+1)4075641770 (Monday through Friday, 8:30 AM – 9:00 PM Eastern). You may also write to us at the following address:
Circles LTD.
Attn: Customer Service
Street Address: 34th Page St.
City, State Zip: San Francisco CA, 94102
Re: Circles Privacy Policy
Circles may, from time to time, change our Policy. We will notify you of any material changes to our Policy as required by law. We will also post an updated copy of this Policy on our Platform. Please check our Platform periodically for updates. If User does not agree with the Privacy Policy, as amended, User must stop using the Services. User is advised that if User does not terminate all use of the Services, User will be deemed to have accepted the Privacy Policy, as amended.
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