Menu
The EU General Data Protection Regulation (“GDPR”) provides residents of the EEA the rights to receive notice regarding the purposes for which your data are processed and the legal basis for our processing, the categories of recipients of your personal information, whether the personal information will be transferred outside these jurisdictions, and the criteria we use to determine how long to retain your data. You also have the right to receive notice about your rights. These rights apply to all residents of these locations, regardless of whether you are a customer, business contact, or member of the workforce.
This Notice supplements the information contained in our Privacy Policy and applies solely to users in the EEA (“consumers” or “you”).
This Notice describes how we collect, use, disclose and otherwise process personal information of individual residents of the EEA, either online or offline, within the scope of the GDPR.
When we use the term “personal data” in this Notice, we mean data that may be used, either alone or together with other information, to identify an individual user, including, without limitation, a user’s name, address, telephone number, username, email address, city and country, geolocation, unique identifiers, picture, or other similar information and includes personal data as defined in the General Data Protection Regulation 2016 /679 of the European Parliament and of the Council of 27 April 2016 in accordance with the GDPR.
For the purposes of this Notice, personal information does not include:
Certain personal information may be transferred to and processed in the US and other countries where we have facilities or in which we engage service providers. The laws in the U.S. regarding personal information may be different from the laws of your state or country. We implement appropriate safeguards to protect your personal information as required by relevant law, including supplemental measures, if we transfer your personal information outside of the EEA.
As described further in the “How We Share Your Personal Information” section of the Privacy Policy, we share personal information internally among 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.
Circles will only process your personal information where we have a legal basis to do so.
The legal basis will depend on the purposes for which we have collected and use your personal information. In almost every case the legal basis will be one of the following:
The legitimate business interests of Circles referred to above include: where it is necessary for Circles to understand our customers in sufficient detail so we can create and publicize new Services, and offer our customers a better experience. For example, we perform analytics on this legal basis as they are necessary to provide you with a tailored experience and so that we can improve, maintain and manage our Services in a way which meets your expectations as a customer.
As a EEA 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):
| EEA Privacy Rights | |
|---|---|
| Right of access, right to data portability, right to request rectification (i.e. correction), and right to request deletion of information (i.e. right to be forgotten, right to erasure) |
You have the right to request that we: • Give you access to, and a copy of your personal information we hold in our systems; • Correct or update inaccurate or incomplete personal information we have about you; • Delete all or some of the personal information we have about you (e.g., if it is no longer needed to provide Services to you). |
| Right to object, withdraw consent, and restrict processing |
You have the right to request that we: • Stop using, and ensure that all third parties stop using, some or all of your personal information (e.g., if we no longer have a legal basis to process it); • Stop contacting you with promotional messages. |
| Right to opt out of automated processing | You have the right to opt-out of automated processing where such processing would produce legal or other similarly significant effects. However, we do not use personal information of residents of the EEA to make automated decisions about you that would have these effects. |
| Right to lodge a complaint | You have the right to lodge a complaint with your local data protection authority about our use of your personal information. |
