CIRCLE ASSESSMENT PRIVACY AND COOKIES POLICY
The type of information we collect from you depends on how you use Circle Assessment. Generally, when using Circle Assessment, we may collect personal information in two ways: (i) you provide it to us, or (ii) it is collected automatically via Cookies (see “Cookies Policy”).
Only registered users can access Circle Assessment. To become a registered user, you must be invited by a Licensing Partner or be a Licensing Partner as defined in the T&C. If you register and create an account on Circle Assessment, we will collect and store that information you provide to us. If you choose to terminate the T&C and request that your data be removed, your user data will be deleted from Circle Assessment.
If you send us personal correspondence, such as emails or letters, we may collect such information into a file specific to you.
USE OF YOUR INFORMATION
We may use your information, including your Personal Information, for the following purposes:
We may use your Personal Information to analyse customer behaviour and to adjust our products and services accordingly, to ensure that it is relevant; to contact you with information about new features and updates about Circle Assessment including offering new functionalities, changing the user experience, and updating functionalities; and other information that you may be interested in based on your account details, websites you have visited and the data you have entered into our websites, your online and offline history and your registered use of Circle Economy or other Circle Economy websites.
Further, we regularly conduct research on the level of satisfaction of users, through the use of 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 make adjustments to Circle Assessment. We may also adapt our promotions on the basis of 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.
We may share aggregated information that does not include Login Information and we may otherwise disclose information that does not identify you (“Non-Identifying Information”) and information about your activities on the site (“Log Data”) with third-parties for industry analysis, demographic profiling, academic research, and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information.
You agree that we may use your Login Information to contact you. By accepting the TOU, you expressly agree that we may contact you as provided herein.
DISCLOSURE OF YOUR INFORMATION
Circle Economy may disclose information it has collected from you when it believes in good faith that the law or legal process requires it, or when it is necessary to do so to protect the rights or property of Circle Economy or others. As a matter of policy, we do not sell or rent any of your Personal Information to third parties without your explicit consent. The following describes some of the ways that your Personal Information may be disclosed in the normal scope of our business and you authorize us to do this for the purposes of the use and operation of the site, or any investigations of the information on Circle Assessment.
Licensing Partner: Circle Economy may share information that you have entered in My Profile with a Licensing Partner.
Service Providers for Our Operations: We may use third parties that we refer to as service providers to facilitate or outsource one or more aspects of our business, including as part of our registration process or to facilitate our mailing lists. Therefore we may provide some of your Personal Information directly to these service providers, or this information may come available to them in the course of our business with them. We recommend you review the privacy policies of these service providers.
Legal Requests: Circle Economy cooperates with law enforcement inquiries, as well as other third parties to enforce laws and intellectual property rights. Therefore, in response to a verified request by law enforcement or other government officials relating to a criminal investigation or alleged illegal activity, we can disclose Login Information including name and email address, and without limiting the above, in an effort to respect your privacy, we will not otherwise disclose your Personal Information to law enforcement or other government officials without a subpoena, court order or substantially similar legal procedure, except when we believe in good faith that the disclosure of information is necessary to prevent imminent physical harm or financial loss; or to report suspected illegal activity.
YOUR PERSONAL INFORMATION RIGHTS
We may retain your information for as long as your account is active or as needed to provide you services, comply with our legal obligations, resolve disputes and enforce our agreements. In certain circumstances we may be required by law to retain your Personal Information, or may need to retain your Personal Information in order to continue providing a service.
Pursuant to GDPR, Circle Assessment users have the following rights regarding their Personal Information.
Circle Assessment acknowledges that you have the right to access your Personal Information. Upon request Circle Assessment will provide you with information about whether we hold any of your Personal Information. You may access, correct, or request deletion of your Personal Information by contacting us at firstname.lastname@example.org. We will respond to your request within a reasonable timeframe in accordance with applicable law. Users are able to retain and reuse their Personal Information for their own purpose.
Circle Assessment acknowledges that you have the right to correct your Personal Information. You can change your username, email address, password, contact and other information by emailing us at email@example.com.
Circle Lab acknowledges that you have the right to remove, or request the removal of, content or information on Circle Assessment. 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 terminate and delete your account.
Circle Lab acknowledges that you have the right to restrict processing of Personal Information for direct marketing purposes. You may, of course, decline to share Personal Information with Circle Assessment, in which case the site will not be able to provide to you some of the features and functionality found on Circle Assessment.
CONTROL OF YOUR PASSWORD
Upon creating your account, we will send you your Login Information. These personal data enable us to administer your account and enables us to ensure the confidentiality and to maintain the security of your information. We are, for instance, able to change your password for you. We are, however, not able to view your password.
OTHER INFORMATION COLLECTORS
Your information is stored on our service provider’s servers in Amsterdam. For more information regarding these services, including the security of the servers, please see Digital Ocean (https://www.digitalocean.com/). These service providers have agreed to maintain the confidentiality, security and integrity of Personal Information collected through Circle Assessment.
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. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to Circle Assessment, including your Personal Information. We do not accept liability for unintentional disclosure. Your information is also stored on our service provider’s servers, and we encourage you to review their terms of service agreements and privacy policies before providing information to them. In the event there is a data breach involving unencrypted Personal Information, we, or our third party partner Digital Ocean, will notify you via email and/or by posting a notice on the affected website.
Amsterdam, Netherlands 1011RX
If you feel that we do not comply with applicable privacy rules you have the right to lodge a complaint with a competent data protection authority.
This information includes your Internet Protocol (“IP”) address - often associated with the portal through which you enter the Internet, like your Internet service provider (“ISP”), your company or your university - browser type, referring/exit pages, pages viewed on Circle Assessment (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data.
Circle Economy gathers this information using third-party services such as Google Analytics for the purpose of monitoring website performance and determining customer service and site needs. Please visit the privacy policies of these third parties to learn about their privacy practices and your opt-out choices.
We use data collection devices such as “cookies” on certain pages of Circle Assessment. “Cookies” are small text files placed in a user’s computer browser to store the user’s preferences. Circle Economy stores cookies that are essential in providing the functionalities of Circle Assessment. Circle Economy does not retain a cookie longer than necessary. We use session cookies and permanent cookies:
Only if you have given prior consent, Circle Economy places cookies that are not strictly necessary for providing the functionalities of the website. Through such non-strictly necessary cookies we collect information about your use of the website 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 website. If you do not consent to cookies being placed, these cookies will be blocked.
Examples of Cookies that we use:
Further information on how to opt-out of cookies can be found below.
We use user activity, to do internal research with the potential to improve Circle Assessment. We may also track the URL that you came to the Assessment from (whether this URL is on Circle Assessment or not), which URL you next go to (whether this URL is on Circle Assessment or not), your computer browser information, your click- and surf behaviour, the length of your session, and your IP address. We do all of these things to better understand, protect and serve you and Circle Assessment and to be able to investigate any allegations against you or us.
By using Circle Assessment (through any device) you agree that this Cookies Policy applies to that use in addition to any other terms and conditions which may apply. By using our Circle Assessment you agree that we can place these types of Cookies on your device. Again, you can block these Cookies using your browser settings.
If you wish to restrict, opt-out, or block the Cookies which are set by any website, including Circle Assessment, 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 websites by making them “trusted websites” 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/choices/ and http://www.youronlinechoices.eu/.
We reserve the right to make changes to our Cookies Policy. Your continued use of Circle Assessment will constitute and confirm your agreement to and acceptance of such changes or modification.