Last updated: 11 December 2023

Circular App Limited
Company No. 3527138
(Registered in England and Wales)

Privacy Policy‍

1. General‍

This privacy notice explains how Circular App Limited (Registered in England and Wales Company No: 3527138) (“The Company”) looks after its Users personal data in all situations where data is collected on all of the Company’s Community Management Platforms, including but not limited to the App, websites, and online portals.
The policy sets out the user’s privacy rights and explains the Company’s approach to privacy and personal data and how the law protects its Users.
The Company is committed to abiding by data protection laws and to be open and transparent in how it uses personal information. The Company takes privacy seriously and this policy and notice has been drafted in accordance with the requirements of the UK Data Protection Act 2018 and the General Data Protection Regulation (“GDPR”).

It is important that you read this Privacy Policy together with the Terms and Conditions, Privacy Notices or Policies that may be provided on specific occasions when we collect or use your Personal Information. This Privacy Policy supplements these notices and policies and is not intended to override them.

2. The Company’s status and details‍

For the purpose of the GDPR, the Company is the Data Controller under the UK GDPR  (as defined therein) and any enquiry regarding the collection or processing of your data should be addressed and emailed to our Data Privacy team at [email protected].

3. Information we collect‍

We will collect, process, and store personal data only for specified, explicit, and legitimate purposes as directly provided to us by Users. Users may do this by accessing the Company’s Community Management Platform or by becoming a User or enquiring about the services.

Personal information covers any information which relates to the user as an identifiable person. Below are examples of the type of data that this may include:
– “Identity Data” may include full names, date of birth, ID number, location, or similar identifier.
– “Contact Data” may include physical address, email address and mobile number.
– “Financial Data” may include credit card details and bank account details.
– “Transaction Data” may include requests for services by a User, transactions between Users, and services that the Company has supplied to the User.
– “Technical Data” may include internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system, platform, and other technology on the devices used to access the Company’s Community Management Platforms.
– “Usage Data” may include enquiries submitted by the User, information supplied, and how Users use and engage with the Community Management Platforms.
– “Marketing Data” may include details of any preference that the User has advised the Company in relation to marketing communications.

The Company may also collect non-personal data such as aggregated data which is data that may be obtained from the Users’ personal data, but which does not directly or indirectly identify the user. This may include Profile and Usage Data detailing how Users use the Community Management Platforms and the areas that user has interacted with.

4. How do we collect your personal data?‍

The Company collects data with direct interactions with Users in person, by phone, email or otherwise or where you have supplied your Identity and Contact Data.
The Company also collects data through automated technologies or interactions with the Community Management Platforms, including use of the web enquiry form or the chat, where we may collect in addition Transaction, Technical, Usage Data and Marketing Data.

5. Data accuracy‍

It is important that the data that we hold about you is accurate and up to date. In the event that your data changes please notify us so that we can update our records or update your user profile on our Digital Platforms.

6. Use of your information‍

We may hold and process personal data that you provide to us in accordance with the GDPR.

The information that we collect and store relating to you is primarily used:
– To enable us to provide services to you and to communicate with you. This may include Identity, Contact, and Transactional data.
– To notify you about any changes to our business, such as improvements to our Community Management Platforms or service/product changes, that may affect our service or relationship with you. This may include Identity and Contact Data.
– If you are an existing User or prospective User, we may contact you with information about goods and services similar to those that were the subject of a previous sale to you or enquiry made, or a discussion held with you. This may include Identity and Contact Data.
– To provide you with our e-newsletters, where you have consented to receive them. This may include Identity and Contact Data.
– Where we need to comply with a legal obligation. This may include Identity, Contact, Transactional and Technical Data.
– Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. This may include all types of data.
– We will only use your personal data for a reason other than the purpose for which it was originally obtained if we consider that we need to use it for that other purpose and have a legitimate interest in doing so.

7. Disclosure of your information‍

There are a range of circumstances where we may disclose your data to third parties. These may include (i) regulatory bodies as required by applicable law, (ii) our suppliers who may be involved in the fulfilment of our services to you (iii) third party marketing, where you have consented for us to do so, and (iv) debt recovery agencies.

8. Controlling the use of your data‍

Where we rely on consent as the lawful basis for processing your data you can revoke or vary that consent at any time. If you do not want us to use your data or want to vary the consent that you have provided you can email us at [email protected] at any time.

9. Data storage and the transfer of your data‍

As part of the services offered to you, for example through our Community Management Platforms, the information you provide to us may be transferred to and stored in countries outside of the United Kingdom (UK) as we may use remote website server hosts to provide the website and some aspects of our service, which may be based outside of the UK, or use servers based outside of the UK. It may also be processed by staff operating outside of the UK who work for one of our suppliers, e.g., our website server host, or work for us when temporarily outside of the UK.

If we transfer or store your personal data outside of the UK in this way, we will take appropriate safeguards to ensure that your privacy rights continue to be protected, as outlined in this privacy policy. Where we use suppliers based in the US, we may transfer data to them if they are certified under the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.

10. Security‍

We take the confidentiality of personal information very seriously and use recognized security and access controls to protect the information from unauthorized access, loss, misuse, alteration, or corruption. We have procedures and processes in place to ensure that your personal information is managed appropriately.
However, we will always recommend that you take your own precautions to protect your own personal data whilst using the Internet, including the Company’s Community Management Platforms.

11. Data retention‍

Except as otherwise permitted or required by applicable law or regulatory requirements, the length of time that we retain, and store data depends on the purpose for which it was collected.
We keep some types of cookies up to 24 months (see use of cookies section).
Where you have requested that we provide you with marketing materials we will retain your data until such time as consent is withdrawn by you.

12. Use of cookies

Our Community Management Platforms uses cookies. We use cookies to gather information about the User computer for our services and to provide statistical information regarding the use of our Community Management Platforms. Such information will not identify you personally – it is statistical data about our visitors and their use of our Community Management Platforms. This statistical data does not identify any personal details whatsoever.
We may also gather information about your general Internet use by using a cookie file. Where used, these cookies are downloaded to your computer automatically. This cookie file is stored on the hard drive of your computer, as cookies contain information that is transferred to your computer’s hard drive. They help us to improve our Community Management Platform service that we provide to you and the way we communicate to you.
All computers have the ability to decline cookies. This can be done by activating the setting on your browser which enables you to decline the cookies. Please note that should you choose to decline cookies, you may be unable to access particular parts of our Community Management Platforms.

13. Your rights‍

If you are residing in the UK, or are a UK resident, the UK GDPR gives you a range of rights in relation to the personal data that we collect from you. You have the right to:

– Access your personal data. This right is commonly known as the ‘data subject access request’ (DSAR) and enables you to receive a copy of the personal data we hold about you. You will not need to pay a fee to access your personal data unless we can justifiably demonstrate that the request is repetitive or excessive. We will respond to all legitimate DSARs within one month, but we may need to obtain further information from you in order to confirm your identity and the legitimacy of the request.
– Request rectification of the personal data. This enables you to have any incomplete or inaccurate data corrected.
– Request erasure of your personal data. This enables you to ask us to delete personal data where there is no justifiable reason for us continuing to retain and process it. We may not always be able to delete the data such as if there is an ongoing contractual relationship between us or if we are legally required to retain the data.
– Object to processing of your personal data where we are relying on consent or our legitimate interests as the justification for processing the data.
– Restrict the processing of your personal data. This enables you to ask us to change the processing of your personal data. For example, you may wish to vary the basis on which we contact you.
– Withdraw consent. Where we are relying on consent to process your personal data, you may withdraw that consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You can exercise these rights at any time by writing to us at the address detailed above, or by email to [email protected].

14. Third party links‍

You might find links to third party websites on Community Management Platforms. If you click a link to a third-party website and visit that site, you may be allowing that site to collect and share certain data about you. These websites should have their own privacy policies, which you should check. We do not accept any responsibility or liability for their policies whatsoever as we have no control over them.

15. Complaints‍

If you wish to raise a complaint regarding our use of your personal data, then please contact [email protected].

16. Changes to this policy

These policies may be updated from time to time.
Please regularly review these policies to be informed of how we are protecting your personal data.

We welcome any queries, comments, or requests you may have regarding this Privacy Policy. Please do not hesitate to contact us.

Last updated: 5_12_23
Version: 1