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Privacy Policy
Updated: September 26th, 2023
1. Introduction
Welcome to Circular Partners’s (the “Company”, “We”, “Us”, “Our”, “Circular Partners”) Privacy Policy.
Circular Partners is committed to protecting your privacy and personal data while you use qwe.com (the “Website”). The following Privacy Policy will inform you as to what kind of information we collect, how we may use it and how it is stored, when you visit our Website. This policy applies regardless of where you visit from and informs you of your privacy rights and how you are protected.
To make the policy easy to understand, we have provided a section for definitions, where legal and technical terms are explained.
The following Articles are covered under our Privacy Policy:
1. Important Information
2. Definitions
3. The Data We Collect About You
4. How (Your) Personal Data is Collected
a. Direct Interactions
i. Contact Forms
ii. Subscriptions
iii. Website Memberships
iv. Purchases
b. Automatic Data Collection
i. Cookies
ii. Web Beacons
c. Third Party and/or Publicly Available Sources
i. Analytics
ii. Payment Processors
iii. Social Media
iv. Google
5. Our Use of Your Personal Data
6. Disclosures of Your Personal Data
7. International Data Transfers and Storage
8. Security of Your Personal Information
9. Do Not Track Policy and Opt-Outs
10. Your Legal Rights
1. Important Information
a. Preface
i. The following Privacy Policy applies to the Website of Circular Partners. The Privacy Policy covers the treatment of Circular Partners Website Users & Members personal data and information, which may be collected at various points across the Website.
ii. This Privacy Policy document outlines the types of personal information that is received and collected by Circular Partners and how it is used.
iii. It is highly recommended that you read this Privacy Policy before proceeding to use the Website, Products, Services and /or Features provided by Circular Partners.
iv. This Privacy Policy is available to view via the “Privacy Policy” link, which can be found throughout the Website.
b. Language of Privacy Policy
i. The Privacy Policy may be available in languages other than English. In the event that other language versions of the Privacy Policy conflict with one another and/or with the English Privacy Policy, then the English Privacy Policy stands final and BINDING.
c. Changes to the Privacy Policy
i. Circular Partners reserves all rights to amend the Privacy Policy that prevail across this Website. This may be done on a regular basis or as the need emerges, as per the sole discretion of Circular Partners.
ii. As and when amendments are made to the Privacy Policy, Circular Partners will post the revised Privacy Policy on its website www.circularpartners.ca (the “Website”) and via links available throughout the Website.
iii. You accept and agree that if you continue to use the Website, its Services and features after the date on which the Privacy Policy has been amended/ updated, your use of the Website, its Services and features will be treated as a form of your acceptance to the revised Privacy Policy.
iv. As the Privacy Policy may be amended from time to time, it is highly recommended that you visit the Privacy Policy page periodically to intimate yourself on the latest (then current) policies.
d. Accepting the Privacy Policy
i. This Privacy Policy applies to all users of the Website, whether you are a “Visitor”, “User”, or a “Registered Member”.
ii. By accessing the Website (or any part of the Website), or Signing up for Membership, or clicking on the agree checkbox, where this function is availed to you, you accept this Agreement.
iii. If you do not want to accept this Privacy Policy or the Terms of Use, you MUST LEAVE THE WEBSITE.
iv. If you breach any part of the Terms, Circular Partners reserves the right to revoke your license to access the Website, block your access, and cancel your account.
v. You may not use this Website, its services and or features if:
1. You do not agree with or Accept the Terms of Use
2. You do not agree with or Accept this Privacy Policy
3. You are not of legal age to enter into this agreement with Circular Partners
4. You are a person who is barred from using the Services under the laws of the United States of America, Canada, India, Australia, United Kingdom, European Union, or any other country/territory including the country/territory of which you are a resident or citizen or from which you attempt to use the services.
2. Definitions
a. The “Website” – The website of Circular Partners, its functionality, features, design, technology, domain(s) www.circularpartners.ca.
b. The “Terms” – The Terms of Use that govern this Website, its Services and features.
c. “Affiliates” and “Third Parties” – Partners and affiliated legal entities across the world, that may provide Circular Partners with software, software platforms and/or technology or services that contribute to Circular Partners providing you or any user with access to the Website and Services.
d. The “Content” – Data, Information, Text files, Audio, Music files, Software(s), or other Sounds, Images, Photographs, Videos or similar – that is uploaded to the Website.
e. “Services” – Web Pages, Features, Software and Products and/or Services provided on the website or otherwise.
f. “Essential Communications” – Any form of communications that enables or facilitates the execution of a contract that you have entered into or are in the process of entering into with Circular Partners. This includes any messages sent by you to Circular Partners, Bookings, Orders, Requests and Purchases.
g. “Non-Essential Communications” – Any form of promotional or marketing communications, offers, updates, blog posts, newsletters and product/service suggestions sent to you by Circular Partners.
3. The Data We Collect About You
a. To provide you with various features and functionality while using the Website, we must process certain information about you. Additionally, to provide you with products, services, answer your questions, take bookings, provide Blog and Newsletter services, we must process certain information about you. The following sections will explain what data is collected, and how it is used.
b. Personal Data or Personal Information means any information about an individual from which that person can be identified. It does not include data where the identity of the person has been removed. Data from which the person’s identity has been removed is referred to as Anonymous Data.
c. We may collect, store, use and transfer different kinds of personal data about you as follows:
i. Identity Data – This includes First Name, Last Name, Username or similar identifier(s).
ii. Contact Data – This includes Email Addresses, Phone Number(s), Mobile Number(s), Billing Address and Shipping Address.
iii. Financial Data – This includes Bank Account(s), Payment Card Details. This information is collected via third party payment gateways that include: PayPal and Square, and as such we DO NOT STORE ANY FINANCIAL DATA.
iv. Transaction Data – This includes details about payments to and from you, Purchase History, including products and/or services you have purchased from Us.
v. Technical Data – This includes IP (Internet Protocol) Address, Your Login Data, Browser Type and Version, Device, Time Zone and Location, Browser Plug-Ins and their Versions, Internet Service Provider, Operating System.
vi. Profile Data – This includes your Username, Password, Purchases and/or Order you have made through the Website, Your Interests, Preferences, Feedback, and Survey Responses.
vii. Usage Data – This includes information about how you use or interact with the Website and/or Products and Services and Features.
viii. Marketing & Communications Data – This includes your preferences for receiving marketing material from us and your communication preferences.
ix. Aggregated Data – This is data that is stripped of any personal identifying information and is as such known as anonymous data. This may include statistical information, including demographics data, which may be used for purposes to help enhance user experience and help us understand our audiences better. If we connect such data back to you so it is identifiable as your data, then we treat it as your personal data and use it in accordance with this Privacy Policy.
d. If You Fail To Provide Personal Data
i. If we a required to collect your personal data by law, or in order under the terms of a contract (to answer a question you may have, respond to a comment you may have, take and/or confirm a booking or an order for a product and/or services, or provide you with information, product(s) or service(s)), and you fail to provide the required personal data when requested, we may not be able to perform the contract we have or are trying to enter into with you and a s a result, we may not be able to provide you with the product, service or functionality. In this scenario, we may have to cancel the service/order/product/features/functionality you are trying to access with us, but we will notify you if this is the case at the time, where reasonable.
4. How (Your) Personal Data is Collected
a. We use various methods of collecting data from you and about you at various points. These include:
i. Direct Interactions – Direct interactions include the completion of any form on the Website. These forms may collect personal data pertaining to your Identity, Contact Information, Financial Data (transaction history and records). This information may be collected via forms on the Website and/or corresponding with us via post, email, phone or other means.
Direct interactions include:
1. Contact Forms
2. Booking Request Forms
3. Product/Service Order Forms
4. Product/Service Purchase Process (Checkout)
5. Member Registration Forms
6. Blog and Newsletter Subscription Forms
7. Contests and Competition Entry/Participation Forms
8. Request for Marketing Communication to be Sent to You
9. Feedback Forms
10. Testimonial/Review Forms
11. Surveys
ii. Automatic Data Collection – Automatic Data Collection includes information that is collected by web technologies to help provide you with a seamless experience on the Website. This data is collected as you interact with the Website and may include information about your browsing behaviour and patterns (while on the Website), the device, software and telecommunications infrastructure you are using to access the Website. We may also receive Technical Data about you if you visit other websites that use our cookies. Please refer to our Cookie Policy for more information.
Automatic Data Collection includes:
1. Cookies
2. Server Logs
3. Web Beacons
4. Other Similar Technologies
These data collections may capture information including:
• Device Attributes – Hardware, Operating System, Software, Signal Strength, Battery Level, Available Storage Space, Browser, Apps.
• Device Operations – This includes information about the operations or use of the device and may include: mouse movements and clicks (that help differentiate between humans and robots).
• Device Identifiers – Device IDs, Version Information (of device, and browsing software).
• Device Settings and Communications Signals – Internet/Mobile Service Providers, Language, Time Zone, IP Address, Connection Bandwidth.
• Cookies – This includes third-party cookies from service providers such as LinkedIn, Facebook, Twitter, Instagram, Google and the Website. To learn more about Cookies and how to disable them or opt-out, please see our Cookie Policy.
iii. Third Party and/or Publicly Available Sources – Personal Data may also be collected via third party and/or publicly available sources. This may include identity and contact data.
Third Party and/or Publicly Available Sources include:
1. Payment Processors (PayPal and Square) based inside and outside of EU.
2. Google Analytics (non-identifiable information regarding website users) – based outside of EU.
3. Other Website Analytics (non-identifiable information regarding website users) – based outside of EU.
4. Social Media (information available on LinkedIn, Facebook, Twitter, Instagram and other Social Media Networks) based inside and outside of EU.
5. Our Use of Your Personal Data
a. Use of Personal Data
Your personal data will only be used as the laws allow. As such the use of your personal data is broken down in the following groupings:
i. Contract Fulfillment – This includes the actions we need to take in order to commence and/or complete a contract we have entered into or are about to enter into. This includes (responding to your questions, requests, providing you with product(s)/Service(s) that you have ordered or purchased or completing a booking request.
ii. Legal Compliance – This includes instances where we are legally obligated to provide information to a governing body, in compliance with the law.
1. Circular Partners will not disclose your personal details, unless explicitly required to do so by:
a. Law
b. Legal process served on Circular Partners
c. Protect and defend the intellectual property rights of Circular Partners, its Members and/or its Affiliates
d. Act in urgent circumstances to protect the personal safety of other Members of Circular Partners, or the public.
2. With reference to the aforementioned non-disclosure agreement, Circular Partners shall send you a Notice in the event of any disclosure that is required.
3. You accept and agree that Circular Partners may collect anonymous information from its Members to monitor and analyze the Website’s statistics. Such information may also be used to optimize Website performance, for marketing and promotional purposes.
iii. Necessary Legitimate Interests – In this instance, we (or a third party) find it necessary for our legitimate interests, so long as they do not override your interests.
iv. Marketing – We aim to provide you with the maximum control possible with regards to how your personal data is used for promotional and marketing purposes. As such we have listed them below:
1. We do not share your data outside of Circular Partners (and its third-party processing partners) for any marketing purposes. The third-party processing partners in reference here are those that enable use to communicate with you via email, phone, post or other means. They do not have our permission to use your personal data for anything other than our marketing efforts.
a. Essential Communications
You may receive essential communications from us when you enter into or are entering into a contract with us. This includes if you send us a message via the Website contact forms, make a purchase on our website, place and order or make a booking or participate in any contest that we may hold.
We may use your name, identity, contact information, technical and/or usage information in order to provide you with product(s), service(s) and features, functionality.
The communications in this regard are essential for us to provide you with product(s), service(s) and features, functionality. You may continue to receive such essential communications even if you have opted-out or withdrawn consent. We do not consider this marketing communications.
b. Promotional and Marketing Communication
We may from time-to-time use your identity information, contact information, profile information, transaction history, technical and usage related information to create a comprehensive view of your interests, likes and dislikes to help us identify what you need or may be interested in. This view may help us in understanding which of our products and/or services you may be interested in.
In this regard, if you have opted-in or provided consent or signed up for our blog and/or newsletters, and/or have booked, ordered or purchased product(s) and/or service from us, signed up for a contest with us, and/or have not expressly withdrawn consent, we may send you communications, updates and offers.
You have a right to withdraw your consent to marketing communications from us at any time. Please contact us at [email protected] or via a Contact Us form on the Website.
We do not rely on consent as a legal basis to process your personal data, as this data is submitted by you in accordance with and in full acceptance of our Terms of Use and Privacy Policy.
Please keep in mind that third-parties such as Google, Facebook and others may use Cookies to track which websites you visit, in order to serve you ads that they believe are relevant to you. If you do not wish to be tracked for such purposes, please refer to our Article 9 and our Cookies Policy, which will help you.
b. How Long We Keep Your Data
Your personal data is stored with us in perpetuity, unless we no longer deem your data to be of any use to us, or unless you expressly ask us to remove all your personal data in accordance with GDPR.
By law we have to keep basic information about our customers (including Contact, Identity, Financial, and Transaction Data) for six years after they cease being customers for tax purposes.
i. If you have currently entered into or are in the process of entering into a contract with Us, your data will be required in order to fulfill the contract(s). This means that if you ask that your data be removed from our systems, you may no longer be entitled to receiving product(s), service(s), website access, access to other features or functionality, regardless of whether payment has been made or not.
ii. If you ask that your personal data be removed from our systems, you understand and agree that we may retain any non-identifiable data and expressly grant us this permission.
iii. If you ask that personal information be removed from our systems, you understand and agree that transaction related information, including personally identifiable information may not be removed.
iv. You may at any time ask us for a copy of your personal data that we may have access to. You will grant us a reasonable timeframe to provide you with this data. Note that this does not mean that your data will be removed from our systems.
6. Disclosures of Your Personal Data
a. In accordance with the Terms, we may have to share your personal data with the parties described below, in order to provide you with access to the Website, Products, Services and Features, as mentioned in Article 5.
b. External Third Parties
i. Service providers acting as processors for us, including CRM system providers, IT service providers and system administrators, who may be located in Canada, Australia, Indian, the United States and/or any other country.
ii. Business partners who want to market their products and/or services to you if you have not opted-out of these disclosures.
iii. Specific third parties including: Google, PayPal, Square, Zoho, Salesforce, Powerhouse, Survey Monkey, WordPress, Wix and Microsoft.
iv. Payment processors based out of Canada, Australia, the United States and/or other countries, who:
1. provide payment processing services
2. prevent, detect, and investigate fraud or other prohibited activities
3. facilitate dispute resolution such as chargebacks or refunds
v. Service providers including accountants, lawyers, advisors, who may be based in Canada, Australia, the United States, India and/or any other country.
vi. Any other business partners, service providers, subcontractors, suppliers, or other third parties that we use to support our business (such as analytics and search engine providers that assist us with website improvements and optimizations). For example, we use Google Analytics to help us understand how our customers use the website (you can read more about how Google uses your personal data here: https://policies.google.com/privacy). You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout .
vii. In the event that we decide to sell part or in full, our business, the third party that agrees to purchase the business may receive your personal data in accordance with the Terms. The new owner(s) may continue to use your personal data in the same manner as described in this privacy policy.
viii. Note that we only do business with and engage trusted third-party service providers and that they do not have access to your personal information without our consent. We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
7. International Data Transfers and Storage
a. While our business is based in Toronto, Ontario, Canada, we may process, store and transfer the personal data that we collect within and to a country outside your own. These countries may have different privacy laws that may not necessarily be as comprehensive as your own country.
b. By visiting or interacting with the Website, submitting personal data using any of the Website’s forms, functionality or features, you understand and agree to any data transfers, storage and processing that we may undertake with reference to this Article 7.
c. If you reside in the European Economic Area, you understand and agree that our and our third parties that process your personal data will require to transfer data outside of the European Economic Area.
d. We ensure that a similar degree of data protection is provided to your data, when we transfer it outside the European Economic Area, by ensuring that our third-party partners’ Agreements include strict data protection policies.
8. Security of Your Personal Information
a. Circular Partners strictly protects the personal information you submit and honors your choices for its intended use in accordance with the Terms.
b. You accept and agree that it is your sole responsibility to maintain the secrecy of your password(s), and that Circular Partners shall not be held responsible for any loss, misuse, unauthorized access, disclosure, alteration or destruction of your content.
c. If you become aware of any loss, misuse, unauthorized access, disclosure, alteration or destruction, please inform Circular Partners immediately and with all details at [email protected] or via the Website’s contact forms.
d. Your personal information is never shared outside Circular Partners, its servers and other software hosted in servers (by third party service providers) without your permission, except under the conditions stated above. Member data is stored in password-controlled servers, with limited access.
e. Circular Partners reserves all rights to use the personal information collected to identify the source of any inappropriate use of information resources managed by Circular Partners, including but not limited to Offensive Content and Illegal Content that is uploaded to or posted on the Website via any communication vehicle(s).
f. Circular Partners reserves all rights to deny Membership, access to its Website, its Services and features to anyone.
g. You accept and agree that Circular Partners reserves all rights to use the personal information collected to identify Members who have:
i. Without authorization accessed online services and network infrastructure
ii. Misused or used without authorization the Circular Partners marks in accordance with the Terms
iii. To protect the personal safety and privacy of Circular Partners’s members, staff and the public.
h. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
9. Do Not Track Policy and Opt-Outs
a. To Opt-Out of or to block or delete Cookies, please refer to our Cookie Policy .
b. To Opt-Out of Advertising Cookies please refer to the corresponding links or our Cookie Policy .
i. Google Targeted Ads
ii. Facebook
iii. Twitter
iv. LinkedIn
c. Other resources:
i. Allaboutcookies.org
ii. Aboutads.info
iii. Youronlinechoices.eu
iv. Understanding online advertising: What are my options
d. You can enable “Do Not Track” or an equivalent setting in your browser at any time. Enabling this feature will tell the websites you visit that you do not wish to have certain information about your browsing collected.
For more information, visit https://www.allaboutdnt.com .
10. Your Legal Rights
It is important for you to know your legal rights when it comes to your personal data.
a. Depending on the laws that govern your personal data (based on where you reside) and under certain circumstances, you have certain rights in relation to your personal data.
These include:
i. Your right to request a copy of your personal data that we may have.
Usually known as “data subject access request”, you can request a copy of the personal data that we store about you and to check that we are lawfully processing it.
ii. Your right to request any correction(s) to your personal data that we may have.
You can at any time contact us to have any personal data that we store about you corrected, or in the case that you find something missing, have it completed.
iii. Your right to have your personal data removed from our systems.
You can at any time ask us to have all your personal data deleted from our systems, so long as there is no good reason for us to continue to store and process it. You may also request that we remove your personal data where you have successfully exercised your right to object to processing, and where your data may have been recorded unlawfully, or in the instance we are required to erase your personal data to comply with a local law. If we are unable to erase all or parts of your personal data (on request by you) for any legal reason, we will inform you as applicable at the time.
iv. Your right to object to processing of your personal data.
You can object to our use of your personal data for marketing purposes. In some cases, we may demonstrate that we have compelling grounds to process your information, and this may override your right to object. We will notify you in the event that this occurs.
v. Your right to request a restriction of how your personal data is processed.
You may request that we restrict the processing of your data if:
1. You need us to verify data accuracy and make corrections
2. Our use of your data may be unlawful, but you do not want us to erase your data
3. You need us to store your data even if we no longer require it, as you require the data for legitimate legal purposes
4. You have objected to our use of your data, but we require you to verify if we have overriding and legitimate grounds to continue using it under the Terms.
vi. Your right to withdraw consent to use your data for marketing purposes.
You can ask us to stop using your data for marketing efforts at any time, by withdrawing consent. This however, does not apply retroactively, and does not cover any processing and marketing that we may have carried out prior to your withdrawal of consent. If you withdraw consent, you may no longer be eligible to receive certain products and/or service from us. We will notify your accordingly at the time.
vii. Your right to request that your personal data be transferred.
You can at any time request us to transfer your personal data to yourself or any third party you nominate. When you request this, your data will be provided to you in a conventional format, that is commonly used and may be machine readable (usually Excel or CSV formats). Note that this only applies to automatically collected information which you initially provided consent for us to use or where we used the information to perform a contract with you.
b. Should you choose to exercise any of these rights, please contact us on [email protected].
c. No Fee Usually Required
i. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
d. Reasonable Time Period to Respond
i. We try to ensure that all legitimate requests are acknowledged within 7 days. We further try to ensure that all requests are executed within 21 days, depending on the complexity of the request. We will keep you notified via email regarding the status of your request(s).
e. Information Required From You to Process Your Request
i. We may need specific information from you in order to process your request. This includes:
1. Information to help us confirm your identity
2. Information to verify that you have the right to exercise any of the rights stated in this Article 10.
ii. This information may be required to ensure that no unauthorised person may access or make changes to your personal data at any time. You understand and agree that we may contact you for more information regarding your request.
11. Our details
This website is owned and operated by Circular Partners.
Our principal place of business is at
Unit 408,
500 Keele Street,
Toronto, ON, M6N 3C9
CANADA.
You can contact us:
(a) by post, using the postal address given above;
(b) using our website contact form;
(c) by telephone, on the contact number published on our website from time to time; or
(d) by email, using the email address published on our website from time to time.
