CIRCLE ASSESSMENT PRIVACY AND COOKIES POLICY

Circle Assessment Privacy & Cookies Policy (“Privacy Policy”) was last updated on 22 May 2018.

This Privacy Policy applies to the Circle Economy content on the internet site located at www.circle-assessment.com along with any related websites, networks, and other services provided by Circle Economy (collectively the “Circle Assessment”). By using Circle Assessment you agree to be bound by the terms and conditions of this Privacy Policy. Capitalized terms not defined in the Privacy Policy have the meanings ascribed to them in the Terms and Conditions of Use (the "T&C"). If you do not agree to the Privacy Policy or the T&C please do not use or access Circle Assessment.

This Privacy Policy describes the information we collect from you and what may happen to that information. By accepting the Privacy Policy, you expressly consent to Circle Assessment’s use and disclosure of your Personal Information (later defined) in accordance with this Privacy Policy.

This Privacy Policy may be updated from time to time, so we advise visitors to consult it regularly for changes. We will notify you of any material changes by prominently posting notice of the new Privacy Policy to the Circle Assessment website and/or by sending you an email to the last email address provided to us. You are advised to consult this Privacy Policy regularly for any changes.

As used in this Privacy Policy, the terms "using" and "processing" information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the Netherlands or internationally.

Circle Economy does not sell or rent your Personal Information to third parties without your explicit consent. Please read this Privacy Policy to learn more about the ways in which Circle Economy uses and protects your Personal Information.

INFORMATION COLLECTED

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”).

You provide personal information to us when you first register for Circle Assessment, such as your e-mail address, password, name (“Login Information”). Your Login Information is held within your account called My Profile. Any of the mentioned information that could be used to identify or contact you is considered “Personal Information” under this Privacy 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.

Other Entities: We may share our data, including Personal Information about you, with our affiliates and subsidiaries. To the extent these entities have access to your information, they will treat it at least as protectively as they treat information they obtain from their users. To the extent allowed by applicable law, these entities follow privacy practices that are no less protective of users than the practices described in this Privacy Policy. Circle Economy may share some or all of your Personal Information, Non-Identifying Data and Log Data with another business entity should we plan to reorganize, spin out, merge with, acquire, or be acquired by that business entity. Should such an event occur, we will require that the new or combined entity follow this Privacy Policy with respect to your Personal Information. If your Personal Information will be used contrary to this Privacy Policy, you will receive prior notice as previously described.

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.

Due to the existing regulatory environment, we cannot ensure that all of your private communications and other Personal Information will never be disclosed in ways not otherwise described in this Privacy Policy. By way of example and without limiting the foregoing, we may be forced to disclose your Personal Information to the government or third parties under certain circumstances or third parties may unlawfully intercept or access transmissions or private communications. Therefore, although we use industry standard practices to protect your privacy, we do not promise, and you should not expect, that your Personal Information or private communications will always remain private.

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 support@circle-assessment.com.  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 support@circle-assessment.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 support@circle-assessment.com 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.

You are responsible for all actions taken with your Login Information. Accordingly, you agree to maintain and safeguard the confidentiality of your Login Information, and to not share your Login Information with any third party. We recommend that you do not disclose your password to any third parties. If you choose to share your username and password or your Personal Information with third parties, you are responsible for all actions taken with your account and therefore you should review that third party’s privacy policy. If you lose control of your password, you may lose substantial control over your Personal Information and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately change your password. If you need help changing your password, please contact support@circle-assessment.com.

OTHER INFORMATION COLLECTORS

Except as expressly stated in the Privacy Policy, this Privacy Policy only addresses the use and disclosure of information we collect from you via Circle Assessment. To the extent that you disclose your information to other parties or other sites throughout the internet, different rules may apply to their use or the disclosure of information you disclose to them. Since Circle Economy does not control the privacy policies of third parties, you are subject to the privacy policies of that third party. We encourage you to ask questions before you disclose your Personal Information to others.

SECURITY

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.

CONTACT INFORMATION

Please direct any questions or concerns you may have about our Privacy Policy to support@circle-assessment.com, or:

Circle Economy

Attn: Circle Assessment General Privacy Policy Inquiries

Mauritskade 64

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.

COOKIES POLICY

Circle Economy is committed to protecting you and any data (anonymous or otherwise) that we collect about you online. This section explains how we use cookies, why, and how this allows us to improve our service. It also provides you with information on how to manage what cookies are stored on your device.

In general, Circle Assessment will gather some technical information automatically. The website uses cookies (and comparable technologies) to give you the best experience. The use of cookies enables Circle Economy and third parties to collect information about you and your internet behaviour and to track you. Using this information, Circle Economy and third parties can tailor content to your interests and profile. In addition, cookies enable you to share information on social media.

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.

If you do not wish to receive any cookies at all, you may set your browser to refuse cookies all together. Most browsers allow you to block and delete cookies. Please note that in that case you may not be able to use certain features on the site and you may be required to re-enter your password or Login Information more frequently. You can usually find out information about how to delete cookies on your browser through a “help” menu.

Examples of Cookies that we use:

Only if you have given prior consent, Circle Economy will use Google Analytics' cookies. These typically last for up to 26 months. If you do not consent to the placement of such cookies, these cookies will be blocked. Google Analytics is a web analysis service that is offered by Google Inc. (Google). Google Analytics uses cookies to analyze the usage of the website by users. Google uses aggregated statistical data to give Circle Economy an insight in the way users use the Website. Google may only provide these data to third parties if Google is required to do so by law, or to the extent third parties processing these data on behalf of Google. You can find more information on Google Analytics here.

 

Further information on how to opt-out of cookies can be found below.

Additionally, you may encounter Cookies or other similar devices used for improving the user experience or providing added functionality on certain pages of Circle Assessment that are placed by third parties. We do not control the use of Cookies by third parties, nor do we have an obligation to do so.

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.