The following information is provided to you to inform you of Circles UK (hereinafter “CIRCLES”) commitments in terms of Personal data protection. CIRCLES builds strong, lasting relationships with its clients, partners and consumers based on mutual trust: making sure that their Personal data is safe and remains confidential is an absolute priority for CIRCLES. CIRCLES is committed to comply with all applicable regulatory and legal provisions governing the protection of Personal data. CIRCLES enforces a very strict privacy policy to guarantee the protection of the Personal data of those who use its websites, portals, applications, and platforms (our “Websites”):
- Users remain in control of their own data. The data is processed in a transparent, confidential and secure manner
- CIRCLES is committed to a continuing quest to protect its users’ Personal data in accordance with the Data Protection Act 2018 and the General Data Protection Regulation 2016/679 of the European Parliament and of the Council of 27th April 2016.
PURPOSE OF THIS POLICY
CIRCLES takes the protection of your Personal data very seriously. We have developed this policy to inform you of the conditions under which we collect, process, use and protect your Personal data on our Website and in the context of the services provided by CIRCLES. This policy covers all users, including those who use the Website and the services without being registered or subscribing to a specific service or account (hereinafter collectively, the “Users”). Please read it carefully to familiarize yourself with the categories of Personal data that are subject to collection and processing, how we use this Personal data and with whom we are likely to share it. This policy also describes your rights and how you can get in touch with us to exercise these rights or to ask us any questions you might have concerning the protection of your Personal data. This policy may be amended, supplemented or updated, in particular to comply with any legal, regulatory, case law or technical developments that may arise. However, your Personal data will always be processed in accordance with the policy in force at the time of the data collection, unless a compulsory legal prescription determines otherwise and must be enforced retroactively.
IDENTITY AND CONTACT DETAILS OF THE CONTROLLER
SODEXO CIRCLES UK LIMITED
Share capital of £100 Address: Avalon House, Breckland, Linford Wood, Milton Keynes MK14 6LD– United Kingdom
Registration number: 05244331
VAT number: 857507986
Telephone: 020 3991 0284
COLLECTION AND SOURCE OF PERSONAL DATA
We will most likely collect your Personal data directly (in particular via the data collection forms on our Website) or indirectly via our service providers and/or technologies on our Website. We undertake to obtain your consent and/or to allow you to refuse the use of your data for certain purposes whenever necessary. You will in any event be informed of the purposes for which your data is collected via the various online data collection forms and via the Cookie Policy.
TYPES OF PERSONAL DATA COLLECTED AND USED BY US
We may specifically collect and process the following types of Personal data:
- the information that you provide when filling in the forms on the Website (for example, for subscription purposes, to participate in surveys, for marketing purposes, etc.);
- the information you provide for the purposes of managing your job application and, where applicable, your recruitment process (e.g.: CV, information relating to your education, your professional experience, awards, diplomas, certificates, attestations, languages spoken, salary expectations, etc.);
- your preferences in receiving marketing from us and our third parties and your communication preferences
- the data relating to your request such as products, quantity, price, billing and delivery addresses including health information about you only where you volunteer and consent to this, for example if you report any specific food allergies after placing an order;
- the transaction data such as payment information and credit/debit card information that is transmitted directly to third parties who process your requests
- information collected through Cookies as defined in our Cookie Policy.
Please find details of the different data collected for the various purposes in the chart (Annex 1).
PURPOSES FOR WHICH WE USE PERSONAL DATA
Personal data may be collected for the following general purposes (a more precise description of the processing of your data can be found in the Annex 1 below):
- Cookies
- Account creation and management
- Customer Relationship Management
- Marketing Management
- Recruitment
In addition, please note that you have the option to click on the dedicated icons of social networks such as Instagram, LinkedIn, etc. that appear on our Websites. When you click on these icons, we may have access to the Personal data that you have made public and accessible via your profiles on the social networks in question. We neither create nor use any separate databases from these social networks based on the Personal data that you have published there, and we do not process any Personal data relating to your private life through these means. If you do not want us to have access to your Personal data published in the public spaces of your profile or your social accounts, then you should use the procedures provided by the social networks in question to limit access to this information. These links to other websites should not be considered as navigation tracking and we decline any responsibility concerning the Personal data protection practices implemented by these third-party companies, each of which acts as a separate Controller of your Personal data on their own perimeter. Once you leave our Website or click on the logo/link to one of these social networks, it is your responsibility to check the privacy policy applicable to that other platform.
LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA
We process your Personal data as part of the performance and management of our contractual relationship with you, in our legitimate interest to improve the quality and operational excellence of the services we offer to you or in compliance with certain regulatory obligations depending on the purpose of processing as identified in the chart in Annex 1. Your Personal data may also be processed based on your prior consent in the event that under certain circumstances, your consent would be requested (e.g regarding health data or for certain types of Cookies). Please find more information about the legal basis for each of our processing in the Annex 1 below .
DISCLOSURE OF PERSONAL DATA
The security and confidentiality of your Personal data is of great importance to us. Therefore, we limit access to your Personal data to only members of our staff who need it to process your orders or provide the requested service. We will not disclose your Personal data to unauthorized third parties. However, we may be required to share your personal data with entities of the Sodexo Group (the Group Circles is a part of) and with authorized service providers (for example: technical providers [hosting, maintenance], consultants, etc.) to which we can call in the context of our benefits. We do not allow our service providers to use or disclose your Personal data, except to the extent necessary to provide services on our behalf or to comply with legal obligations. In addition, we may share Personal data about you:
1. if required by law or legal process,
2. in response to a request from public authorities or other officials, or
3. if we believe that the transfer of this data is necessary or appropriate to prevent any physical damage or financial loss or in connection with an investigation concerning a suspected or proven illegal activity.
STORAGE PERIOD OF YOUR PERSONAL DATA
We will store your Personal data only for as long as necessary to fulfill the purposes for which it was collected and processed. This period may be extended, if applicable, for any amount of time prescribed by any legal or regulatory provisions that may apply. To determine the retention period of your Personal data, we take into consideration several criteria such as:
- The purpose for which we hold your Personal data (e.g. when you purchase products on our Websites, we keep your Personal data for the duration of our contractual relationship);
- Our legal and regulatory obligations in relation to that Personal data (e.g. accounting reporting obligations);
- Whether you are an active user of our services, you continue to receive marketing communications, or you regularly browse or purchase off our Websites or whether you do not open our emails or visit our Websites; For instance, if you have agreed to receive marketing communications, we keep your Personal data until you: (i) unsubscribe from receiving marketing communications (ii) request we delete your Personal data, or (iii) after a period of inactivity (i.e. where you have not interacted with us for a period of time). This period is defined in accordance with local regulations and guidance;
- Any specific requests from you in relation to the deletion of your Personal data or Account;
- Any statutory limitation periods allowing us to manage our own rights, for example the defense of any legal claims in case of litigation; and
- Any local regulations or guidance (e.g. regarding cookies).
Please find more information about the storage period of your Personal data in Annex 1 below.
SENSITIVE PERSONAL DATA
As a general rule, we do not collect sensitive Personal data via our Websites. “Sensitive Personal data” refers to any information concerning a person’s racial or ethnic origins, political opinions, religious or philosophical beliefs, union membership, health data or data relating to the sexual life or the sexual orientation of a natural person. This definition also includes personal data relating to criminal convictions and offenses. In the event that it would be strictly necessary to collect such data to achieve the purpose for which the processing is performed, we will do so in accordance with local legal requirements for the protection of Personal data and, in particular, with your explicit prior consent and under the conditions described in this policy.
PERSONAL INFORMATION AND CHILDREN
The Website is intended for use by adults who have the capacity to enter a contract under the laws of the country in which they are located. Child users under the age of 16, or those without legal capacity, must obtain the consent of their legal guardians before submitting their data on the Website. The age limit of 16 can be reduced to 13 depending on the local legislation of your place of usual residence. Our Website is intended for a general audience and is not directed to children under the age of 13. Please contact us if you believe that we may have collected information from your child, and we will work to delete it.
YOUR RIGHTS
Circles is committed to ensure protection of your rights under applicable laws. You will find below a table summarizing your different rights:
Right of access and rectification
You can request a copy of the Personal data we hold about you. You may also request rectification of inaccurate Personal data, or to have incomplete Personal data completed.
Right to erasure
Your right to be forgotten entitles you to request the erasure of your Personal data in cases where:
(i) the data is no longer necessary for the purpose for which it was collected;
(ii) you choose to withdraw your consent;
(iii) you object to the processing of your Personal data;
(iv) You have objected to the use of your data for direct marketing purposes.
(v) your Personal data has been unlawfully processed;
(vi) there is a legal obligation to erase your Personal data;
(vii) The data was collected from you as a child for an online service
Right to restriction of Processing
You may request that processing of your Personal data be restricted in the cases where:
(i) you contest the accuracy of your Personal data;
(ii) Circles no longer needs your Personal data for the purposes of the processing;
(iii) you have objected to processing for legitimate reasons;
(iv) the processing of your Personal data is unlawful and you prefer the restriction of their use instead of their deletion
Right to data portability
You can request, where applicable, the portability of your Personal data that you have provided to Circles, in a structured, commonly used, and machine-readable format you have the right to transmit this data to another Controller without hindrance from Circles where:
a) the processing of your Personal data is based on consent or on a contract; and
b) the processing is carried out by automated means. You can also request that your Personal data be transmitted to a third party of your choice (where technically feasible).
Right to object to Processing
You may object (i.e. exercise your right to “opt-out”) to the processing of your Personal data particularly in relation to profiling or to marketing communications. When we process your Personal data on the basis of your consent, you can withdraw your consent at any time.
Right not to be subject to automated decisions
You have the right not to be subject to a decision based solely on automated processing, including profiling, which has a legal affect upon you or significantly affects you.
Right to lodge a Complaint
You can choose to lodge a Complaint with the Data Protection Supervisory Authority in the country of your habitual residence, place of work or place of the alleged infringement, regardless of whether you have suffered damages. In the UK, the Data Protection Supervisory Authority is the Information Commissioner’s Office (www.ico.org/uk). You have also the right to lodge your Complaint before the courts where Circles UK has an establishment or where you have your habitual residence.
You may, at any time, exercise any of the above rights or contact us with any data protection related queries or concerns by completing the request form and sending it to circles.privacy@sodexo.com as indicated in the privacy notices and/or the privacy policies provided to you at the time of the collection of your Personal Data or by completing and submitting the dedicated request webform. For more details, please consult the Local Data Protection Rights Policy.
TRANSFER OF PERSONAL DATA
As Circles is an international group, your Personal data may be transmitted to internal or external recipients that are authorized to perform services on our behalf. Some of these recipients are located in countries outside of the European Union or the European Economic Area which do not offer an adequate level of Personal data protection. Those recipients can also be other entities of the Sodexo Group. Sodexo Group has entities in over 60 countries who could be recipients of your data for the purposes listed above. In addition, Circles has processors that can be located in the following countries: United Kingdom and United States of America.
Your personal data may be transferred to our US-based provider for marketing management purposes. To guarantee the security and confidentiality of Personal data thus transmitted, we will take all necessary measures to ensure that this data receives adequate protection, such as entering into data transfer agreements with the recipients of your personal data based on the European Commission’s standard contractual clauses (“SCCs”) or other valid transfer mechanisms and we carry out, in accordance with the European Court of Justice’s decision of 16 July 2020 “Schrems II” (Case C 311-18) and with the guidance of the European Data Protection Board, a risk assessment of the transferred data. If you would like to receive a copy of the safeguards in place to secure data transfers outside the European Economic Area, please refer to the Section “How to contact us”.
SECURITY
We implement all possible technical and organizational security measures to ensure the security and confidentiality of the processing of your Personal data. To this end, we take all the necessary precautions taking into account the nature of the personal data and the risks linked to their processing, in order to ensure the security of the data and in particular to avoid any deformation, deterioration or unauthorized access by third parties (physical protection of premises, authentication procedures with personal and secure access via confidential identifiers and passwords, connection log, encryption of certain data, etc.). We regularly conduct audits to verify the proper operational application of the rules relating to the security of your Personal data. Nevertheless, you also have a responsibility to ensure the security and confidentiality of your Personal data so we invite you to remain vigilant, especially when using an open system such as the Internet.
LINKS TO OTHER WEBSITES
Occasionally, we provide links to other websites for convenience and information. These websites operate independently from our Website and are not under our control. These websites are operated by third parties with their own privacy recommendations or terms of use which we strongly advise you to read. This privacy policy does not apply to any other third-party websites. We accept no responsibility for the content of these websites, the products and services offered there, or any other use that may be made of them.
UPDATES OF OUR ONLINE PRIVACY POLICY
We may update or amend this policy as and when needed. In this case, amendments will only become applicable after a period of 30 business days from the date of the amendment. Please consult this page from time to time if you want to be informed of any possible changes.
UNSUBSCRIBING AND OPT-OUT
If you have subscribed to certain services through our Website and you no longer want to receive emails, please consult the “unsubscribe” link at the bottom of any email message you receive from us, send us an email at circles.privacy@sodexo.com.
HOW TO CONTACT US If you have any questions or comments with regard to this policy, please do not hesitate to contact us at the following address: circles.uk@sodexo.com.
Annex 1: INFORMATION ABOUT THE PROCESSING OF YOUR PERSONAL DATA
The following sections will each include Purpose of Processing, Personal Data Collected, Legal Basis of the Processing and Retention of the Personal Data.
Account creation and Management
- Send an initial communication via email to invite you to register and use our Sites and Services
- Name, Email
-In order to take steps at the request of the data subject prior to entering into a contract Consent
- If you are one of our customers, these communications may be sent to you for the duration of our commercial relationship, then for three (3) years after the end of this relationship or of the last contact you initiated. If you are not yet sure whether you want to benefit from our products and Services, and you are still in the prospecting phase, we can send you communications on our offers and products for a period of three (3) years from the last contact you initiated.
- Register you as a user and create an account for you on our Site
- Name, Email, ID, user and password
- Performance of a contract to which the data subject is party
- We will keep your Personal data in your customer account (s) until you delete your account.
Customer Relationship Management
- Manage and monitor our relationships with existing and potential customers
- Name, Email
- Contract and legitimate interest
- We will keep your Personal data for the duration of our commercial relationship, after which only the data necessary for pre-litigation or litigation purposes will be archived until the legal prescription is acquired. The usual limitation period in civil and commercial matters is six (6) years. In the event of a dispute, this data is kept for the duration of the procedure and until the expiration of ordinary and extraordinary remedies.
- Respond to your requests for information, searches, newsletter and other content.
- Name, Email
- Legitimate interest and consent
- We will send you our newsletter until you unsubscribe.
- Access whether you are eligible for certain products and Services
- Name Email Age
- Contract Legitimate interest
- We will keep your Personal data for the period necessary to carry out those checks
- Process and deliver your order
- Name Email Information on your order
- Contract
- We will keep your Personal data for the duration of our commercial relationship, after which only the data necessary for pre-litigation or litigation purposes will be archived until the legal prescription is acquired. The usual limitation period in civil and commercial matters is six (6) years. In the event of a dispute, this data is kept for the duration of the procedure and until the expiration of ordinary and extraordinary remedies.
- Comply with legal obligations
- Legal obligations
- We will keep your Personal data for the duration of the procedure, plus the period of acquisition of legal requirements. The usual limitation period in civil and commercial matters is six (6) years from the end of the contract.
Marketing Management
- Conduct surveys and gather statistics
- Name Email address Cookies
- Legitimate interest
- We will keep your data for a period of three (3) years from the last contact you initiated
- Respond to your requests for newsletter or other content
- Name Email address Cookies
- Consent
- We will send you our newsletter until you unsubscribe.
- Manage, organize and improve of the competitions and related promotional operations
- Name Email address Cookies
- Consent
- We will keep your data for a period of three (3) years after the end of the competition or the draw.
- Send commercial communications about products and services that may be of interest to you
- Name Email address Cookies
- Consent
- If you are one of our customers, these communications may be sent to you for the duration of our commercial relationship, then for three (3) years after the end of this relationship or of the last contact you initiated. If you are not yet sure whether you want to benefit from our products and services, and you are still in the prospecting phase, we can send you communications on our offers and products for a period of three (3) years from the last contact you initiated.
- Profile your Personal data to use internally to help us understand your motivations, values and needs
- Name Email address Cookies
- Consent, Legitimate interest
- If you are one of our customers, these communications may be sent to you for the duration of our commercial relationship, then for three (3) years after the end of this relationship or of the last contact you initiated. If you are not yet sure whether you want to benefit from our products and services, and you are still in the prospecting phase, we can send you communications on our offers and products for a period of three (3) years from the last contact you initiated.
Recruitment
- Assess your skills, qualifications, and suitability for the role
- Name Email address Information given with your application
- In order to take steps at the request of the data subject prior to entering into a contract
- We will keep your data for a period of six (6) months after we received your job application
- Carry out background and reference checks
- Name Email address Information given with your application
- Legitimate interest
- We will keep your data for the period necessary to carry out those checks
Definitions
Beneficiary
Persons designated by the Client as the beneficiary of Circles concierge services.
Cookies As defined in the Cookie Policy
Controller
The Circles entity which, alone or jointly with other Circles or Sodexo entities, determines the purposes and means of the processing of personal data.
Client
legal entity which has concluded a contract with Circles to set up and manage a concierge service.
Partners
Any independent natural or legal person selected by Circles to perform certain services offered as part of a concierge service.
Personal data
Any information relating to an identified natural person or one that can be directly or indirectly identified by reference to an identification number or to one or more factors specific to this person. Processing
Any operation or set of operations which is performed on Personal data or on sets of Personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Processor
A legal person – which processes personal data on behalf of the controller.
Us or Our
Circles acting as a Controller.
You or Users
any Website user and, including but not limited to, Clients, Beneficiaries or Website visitors.
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