DATA PROTECTION POLICYPRIVACY POLICY Effective Date: October 26, 2021
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. Please read them carefully in order to familiarize yourself with the categories of personal data which are the subject of collection and processing, the way in which we use this data and with whom we may share it. This policy also describes your rights and how you can contact us to exercise these rights or to ask us any questions you may have regarding the protection of your personal data. This privacy policy may be modified, supplemented or updated, to comply with any legal development, regulatory, jurisprudential or technical that may arise. However, your personal data will always be treated in accordance with the policy in force at the time of data collection, unless a compulsory legal prescription provides otherwise and must be applied retroactively. In addition to this privacy policy, the use of the Website and services requires acceptance of the conditions of use of the Website.
DEFINITIONS
“Personal data”: any information concerning an identified natural person or who can be identified directly or indirectly by reference to an identification number or to one or more factors specific to that person.
“Beneficiary”: persons designated by the Customer as beneficiary of Circles concierge services.
“We” or “our”: CIRCLES (hereinafter “Circles”), 800 South Street, Suite 195, Waltham, MA 02451, represented by Circle Company Associates, Inc. a subsidiary of Sodexo, Inc. (hereinafter “Sodexo“).
“You”: any user / visitor to the website.
“Website”: the Circles websites available at www.circles.com and my.circles.com as well as any client website hosted under a domain managed by Circles.
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 (in particular via our service providers and / or technologies on our Website, or data communicated by your employer). We are committed to obtaining your consent and/or allowing you to refuse the use of your data for certain purposes whenever necessary. In any event, you will be informed of the purposes for which your data is collected.
TYPES OF PERSONAL DATA WE COLLECT AND USE
We may specifically collect and process the following types of personal data:
- the information you provide when filling out the Website forms (for example, to subscribe, participate in surveys, for marketing purposes, etc.
- the information you provide for authentication purposes;
- the information you provide for the fulfillment of an order or to provide a service; and
- through “messages”, comments or other content that you post on the Website.
- to respond to your requests such as requests for information, research, newsletter or other content;
- to provide the services and offers ordered on our Website and / or in one of our establishments;
- to conduct surveys and collect statistics;
- to personalize and improve your experience on our Website;
- offer you our products and services and / or those of our partners; and
- any other purpose of which we will inform you, if necessary, when we collect your data.
- if required by law or legal process,
- in response to a request from public authorities or other officials, or
- email circles.privacy@sodexo.com;
- fill out our GDPR Data Subject Request form at https://privacyportal-eu-cdn.onetrust.com/dsarwebform/c51cde17-e99e-4699-80ce-892748f9ad1a/941d37eb-3727-47db-8040-4e7282414099.html; or
- send a letter to: