Effective Date: July 18, 2014
Data Privacy at Circle Company Associates, Inc.
What Information Do We Collect?
When corporations (such as an organization you work for or of which you are a customer (“Clients”) sign up for Circles’ services, or when you first contact Circles for services, we will collect basic contact information, such as name, email address, address and phone numbers. Circles collects this contact information so that we can communicate with you regarding your requests for personal services as well as deliver relevant content to you. If you were introduced to Circles as an employee or customer of an organization that is a Circles’ client, we may also collect your job title and one or more unique identifiers (for example, your employee code). Beyond this basic contact information, members may also have the option of providing additional information such as home and mobile contact information.
Circles may also collect information from you about your personal or professional interests, demographics and your experience with our services and the products and services provided by our third party service providers. Circles may also ask you for your age/date of birth, marital status, and gender in order to tailor its services to suit you or to fulfill a request you place.
When making a request, members are asked to provide information about the service desired and any additional information needed to complete the member’s request.
How Do We Use Personal Information We Collect?
We use personal information collected in order to process the service requests that you make and to communicate about those service requests to our third party service providers who may fulfill your requests. We also use personal information collected to offer services to you that may be of interest to you and to tailor communications that are sent to you. Subject to any opt-out exercised to you as described below, Circles may use your personal information for marketing purposes so that we may provide you with information about products and services which may be of interest to you. Circles may also use your personal information for market research purposes including carrying out member surveys either directly or through a third party survey entity.
In What Circumstances Do We Disclose Personal Information?
If you place a request for service, Circles will provide your personal information to one or more third party service providers as reasonably necessary for the service provider to consider or fulfill your request. If the service you request includes air travel we may be required by law or regulation to disclose your personal information (or a portion of it) to the relevant authorities, depending on your travel destination and/or your route.
Subject to your opt out as described below, we may use your personal information to send you direct marketing regarding our services. That marketing information may be provided to you by post, email, telephone, SMS or any other form of electronic message or by other methods which may become relevant from time to time. Use of your personal information by any service provider you engage with through our services will be subject to the privacy policies of that service provider, not Circles, and we encourage you to review the privacy policies of any such third party provider before making any disclosure to, or proceeding with any transaction with, any of these third parties.
We may share aggregate information with our clients and potential clients to indicate trends in usage and consumption of our services and for reporting purposes. We may also share aggregate information with our service providers in order to enhance your experience on our site as well as on their sites. This aggregate information is not linked to any personal information that can identify any individual person.
Circles may share your personal information: (a) with our professional advisers and suppliers that provide products and services to help us in running our business; (b) with our affiliated companies (that is, companies under common ownership and control with Circles) in order to fulfill your service request, meet our obligations to our corporate clients, or for processing, storage and handling; (c) with our Clients with regard to frequency of usage of Circles’ services or any complaints we may receive; (d) if you receive our services as a result of being a customer of a Client, for quality control purposes; and (e) with third party survey entities, so that they may provide you with an opportunity to participate in surveys about Circles services. Circles may also need to disclose personal information when required by law or when we have a good-faith belief that such action is necessary to comply with an appropriate law enforcement investigation, judicial proceeding, court order, or legal process served on our Web site. If all of a portion of Circles or its businesses are acquired by a third party, personal information may be included in the data transferred to the acquirer.
Cookies & Log Files
We use IP addresses to analyze trends, administer the site, track members’ movement through the site, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.
Circles partners with a number of third party service providers who fulfill service requests submitted by members, provide content for our website, and to whose websites we may link. Circles is not responsible for the privacy practices of our third party partners or of any linked third party websites, and this privacy statement does not apply to third party websites or to co-branded sites operated by Circles’ business partners. You should review the privacy policies on any third party websites and make whatever investigation you feel necessary or appropriate before making any disclosure to, or proceeding with any transaction with, any of these third parties.
Circles takes commercially reasonable technical and organizational measures designed to protect your personal information against unauthorized disclosure, access, or use. If you have any questions about the security at our web site, you can send an email to firstname.lastname@example.org.
Correction/Updating Personal Information
Members can update their personal profile by contacting us through one or more of the methods described in the “How to Contact Us” section below.
Members have the right to opt-out of receiving direct marketing from us. If you wish to exercise this option, click on the “unsubscribe” link on any e-mail message you receive from us or email us or write to us as described in the “How to Contact Us” section below.
Notification of Changes
How To Contact Us
If you have questions or concerns regarding this statement, you may contact us at:
- Email: email@example.com
- Telephone: (781) 902-2800
- Postal Mail: Privacy Request, Circles, 400 5th Avenue, Suite #505, Waltham, MA 02451