This policy was last updated on 11-25-2020
"Circle Economy" a legal entity with its registered office at: Mauritskade 64, 1092 AD Amsterdam, registered number: KVK: 52051048, acts as a Data controller and respects your privacy and adheres to the applicable EU General Data Protection Regulation ("GDPR").
In the following, you are informed which personal data we may gather, for which purpose it may be processed and what cookies may be employed during your visit and use of the Platform.
1.1. first name, last name, email address, when you register to the Platform (the "Login Information").
Your email address is not displayed publicly on the Platform, but it will be displayed to Platform administrators.
1.2. your photo, location, interests, phone number, other information (if uploaded to My Profile and made visible to other Users).
Except for first and last name it is not necessary for a User to disclose personally identifiable information publicly to fulfill the purpose of the Platform. It is each user's decision as to whether they add additional personal Information to their My Profile section or upload a photograph/image of themselves and opt to make these visible to other Users as part of My Profile.
If you send us personal correspondence, such as emails or letters, or if Other Users or third parties send us correspondence about your activities or postings on the Platform, we may collect such information into a file specific to you.
Further, we regularly conduct research on the level of satisfaction of Users, using feedback surveys. We use your responses to such surveys for quality assessments and to improve your customer experience.
Based on the information above, we can adjust the Platform. We may also adapt our promotions based on our analysis. We may also perform research into market trends through statistical analysis to evaluate and adapt our products and marketing to new developments, but research results are only reported on an aggregated basis.
Our legal basis for collecting and using the personal data described above will depend on the personal data concerned and the specific context in which we collect it. However, we usually will process personal data only (i) where we need the personal data to provide the services or execute the contractual relationship with you, (ii) where we have you consent to do so, or (iii) where the processing is in our legitimate interests and not overridden by your rights. In some cases, we may also have a legal obligation to collect personal data from you.
Other Users: When you post Contributions to the Platform, including comments, certain Personal Information about you, such as your user name, identifying photo, and Profile Content may - and likely will be - displayed on the Platform. More sensitive Personal Information, such as your postal address, e-mail address, phone number, will NOT be displayed on the Platform. Other Users, including Users who come to Circle Lab via a link posted on a third-party Platform, including third party sites, will have access to the publicly displayed information. We are not responsible for privacy practices of the Other Users who will view and use the posted information you choose to make available on or through Circle Lab. You should therefore be mindful of these types of disclosures when selecting a User name or choosing the photograph to use with your account.
Service Providers: We may use third party vendors, service providers, contractors or agents, such as Amazon Web Services, Mailchimp, Sparkpost to facilitate or outsource one or more aspects of our business, including as part of our registration process or to facilitate our mailing lists.
Other Entities: We may share our data, including Personal Information about you, with our affiliates and subsidiaries, which may help us to process it.
According to the applicable laws as well as Art 13 et seq GDPR, you have the right to request access to personal data; request rectification of personal data; request erasure of personal data; request restriction of processing of personal data; request data portability; object to the processing of personal data (including objection to profiling;); withdraw consent to processing of your personal data, where applicable. Please directly contact us in these cases.
If you think your privacy rights have been breached, you may lodge a complaint with an authority of the European Union country of your habitual residence, place of work or of an alleged infringement. Contact information for these authorities can be accessed at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
You agree to maintain and promptly update and keep accurate, current and complete any information provided to Circle Lab as part of My Profile. You can change your username, email address, password, contact and other information by going to My Profile. Your previous Contributions will be associated with the updated information. You may update or correct your profile information and preferences at any time on the Platform or by emailing us at email@example.com.
If you would like us to delete your account record in our system, you are able to do so by contacting us at firstname.lastname@example.org with a request to delete your account, providing your username, and entering "Delete my account" in the subject line. We will use commercially reasonable efforts to honor your request. Removal of this content or information from public view does not guarantee complete or comprehensive removal. After your removal request has been honored, we may retain an archived copy of your records as required by law or for legitimate business purposes. We are not required to remove your posted content or information if it has been rendered anonymous or if we are required by law to retain it. Additionally, we do not have control over third parties (e.g., Other Users) who may have copied or reposted this information. If you have included Login Information in online forum postings or in information or communications shared with Other Users, you may not be able to update, correct or delete this information from the Platform.
If you delete your account on the Platform, your user data will be removed from the Platform and your My Profile will be deleted, however your Contributions will still be visible without attributions to you.
The administration of your login/password information and authentication is provided by Amazon Cognito. This enable us to administer your account and enables us to ensure the confidentiality and to maintain the security of your information. We are not able to view or change your password.
Your information is stored on our service provider's servers. For more information regarding these services, including the security of the servers, please see Amazon Web Services (https://aws.amazon.com/). These service providers have agreed to maintain the confidentiality, security and integrity of Personal Information collected through the Platform.
We use reasonable physical, procedural, technical and administrative security measures to protect your Personal Information against loss or theft as well as unauthorized access and disclosure to protect your privacy.
If you are an underage person, you shall not use this Platform and are obliged to leave it immediately. This Platform shall not be used and shall not be intended to collect information on underage users and advertise information on services for children without the consent of their parents. If the Circle Economy becomes aware of the use of the Platform by an underage person and provision of their data personal data by them, or in cases of parents' or legal representatives' requests for deletion of personal data, such information will be deleted within the reasonable term, and the Platform will make every effort not to store and process the personal data of the underage person.
As most Platforms and mobile applications, we use automated collection of information about you, cookies and social media plug-ins, provided that you have granted your consent to their use (e.g. though the banner on our Platform) in order to optimize our services and the Platform, unless cookies are required for strictly technical functioning of the Platform.
Circle Economy stores cookies that are essential in providing the functionalities of the Platform. Circle Economy does not retain a cookie longer than necessary. We use session cookies and permanent cookies:
- A session cookie can track usage such as the webpages you visit and what options you use. When you close the internet browser, the session is ended, and the cookie is deleted.
- A permanent cookie enables the Platform to recognize you at a subsequent visit.
Only if you have given prior consent, Circle Economy places cookies that are not strictly necessary for providing the functionalities of the Platform. Through such non-strictly necessary cookies we collect information about your use of the Platform and remember your preferences. Examples of collected information are which pages are visited and the length of a user session. Through these cookies we aim to improve your user experience of our Platform. If you do not consent to cookies being placed, these cookies will be blocked.
Login cookies. These help to distinguish you from other users and enable us to provide you with a good experience. The information they use is your email address and an alphanumeric session key to help us recognise you when you return to the Site or relevant Community. It will typically last for two weeks from the time you log in if you remain logged in, or it will be deleted immediately when you log out.
Statistic tracking cookie: This is used to recognise that a user has previously visited the Platform. No identifiable personal information is contained within this cookie. It will typically last for 12 months.
Circle Economy Platform also provides ads with Google DoubleClick and/or AdSense services (including placed from the local domain). Google will combine the data of analytics cookies with DoubleClick and/or AdSense data.
We use User activity, including Users' My Profile, on the Platform to do internal research with the potential to improve the Platform. We may also track the URL that you came to the Platform from (whether this URL is on the Platform or not), which URL you next go to (whether this URL is on the Platform or not), your computer browser information, your click- and surf behavior, the length of your session, and your IP address. We do all these things to better understand, protect and serve you and the Platform and to be able to investigate any allegations against you or us.
If you wish to restrict, opt-out, or block the Cookies which are set by any Platform, including this Platform, you should do this through each individual browser setting and on each device you use to access the internet. You can allow Cookies from specific Platforms by making them "trusted Platforms" in your internet browser. For more information on how to do this, and how to change your browser settings, you may wish to visit http://www.aboutads.info/choic... and http://www.youronlinechoices.eu/.
Coöperatieve Circle Economy U.A.
Mauritskade 64, 1092 AD, Amsterdam
In respect of all questions related to the processing, place of storage and use of the personal data, please contact email@example.com.
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