CIRCLE ECONOMY Privacy & Cookies policy

This Privacy Statement provides information on the processing of personal data on the internet site located at www.circle-economy.com along with any related websites, networks, and other services provided by Circle Economy U.A., hereafter Circle Economy, we or us. This particular site is operated and maintained by the Circle Economy entity referred to in this website.

This Privacy Statement may be changed over time. The most up-to-date Privacy Statement is published on our website. This Privacy Statement was last changed on 5 December 2019. You can store or print this Privacy Statement by using the buttons at the top of this page.

WHEN DOES THIS PRIVACY STATEMENT APPLY?

This Privacy Statement is applicable to the processing by Circle Economy of all personal data of its customers, suppliers and business partners and other individuals. This Privacy Statement does not address the processing of personal data of employees in the context of their employment relationship with Circle Economy.

WHO IS RESPONSIBLE FOR COLLECTING YOUR PERSONAL DATA?

Circle Economy and/or its group companies are the controllers of the processing of all personal data that fall within the scope of this Privacy Statement. This Privacy Statement indicates what personal data are processed by Circle Economy and for what purpose, and to which persons or entities the data will or may be provided. Circle Economy may share your personal data with third parties (see Cookies Section)

FOR WHICH PURPOSES DO WE PROCESS YOUR PERSONAL DATA?


Purpose

To provide our services to you, which may include communicating with you about your use of our websites, allowing you to download our reports, responding to your inquiries, troubleshooting problems, connecting with you on social media and for other customer service purposes

To better understand how you access and use our websites, both on an aggregated and individual user basis, on individual website pages and across them in order to improve our websites and respond to user desires and preferences, and for other research and analytical purposes;

To comply with the law, Circle Economy may process your personal data and may disclose your personal data to government institutions or supervisory authorities. This could, for example, be the case where tax or business conduct related obligations apply.

For marketing, and promotional purposes, including, for example, to send you news and newsletters, promotions, or to otherwise contact you about projects, opportunities or information we think may interest you provided you have opted into receiving such communications from us; to administer surveys and questionnaires

For the assessment and acceptance of a customer, supplier or business partner or other administrative purposes such as due diligence and screening against publicly available government and/or law enforcement agency sanctions lists

For administrative purposes such as sending reports, invoices and making payments, to deliver or receive and administer our or your products or services, and to further execute our agreement, including for the delivery of customer services

For business process execution and internal management in the performance and organisation of our business, such as general management, order management and internal management; for audits and investigations, to implement business controls, and to manage and use customer, supplier and business partner directories; for finance and accounting, archiving and insurance purposes, legal and business consulting and in the context of dispute resolution

For organisational analysis and development, to create management reports and to analyse Circle Economy's business

To check compliance with Circle Economy policies and regulations, such as the Code of Ethics and the IT Policy. During monitoring activities, your personal data may be accessed and viewed.


Personal Data Collected

Name, username, contact details, email address, organisation, role, correspondence, communication channel you have chosen to use to connect with us, and other personal data you supply in your message.

Email address, name, correspondence with us, IP-address, pages visited on our websites, click- and surf behaviour, the length of sessions, delivery of newsletters, etc.

Address, email address, name, payment information, payment history, Chamber of Commerce and VAT details, and tax details

Name, contact details, correspondence, and other personal data necessary to get your feedback

ON WHAT LEGAL GROUNDS DO WE PROCESS YOUR DATA?


Circle Economy processes data only if and to the extent that at least one of the following applies:

  • you have given consent to the processing of personal data for one or more specific purposes;
  • processing is necessary for the performance of a contract to which you are party to or in order to take steps at your request prior to entering into a contract;
  • processing is necessary for compliance with a legal obligation to which we are subject;
  • processing is necessary in order to protect your vital interests or the interests of another natural person;
  • processing is necessary for the performance of a task carried out in the public interest;
  • processing is necessary for the purposes of the legitimate interests pursued by us or by a third party


HOW LONG DOES CIRCLE ECONOMY KEEP YOUR DATA?


Circle Economy will retain your data until it is no longer needed for historical, statistical or research purposes, or until it is no longer necessary to be preserved for possible future legal claims.


WHO HAS ACCESS TO YOUR PERSONAL DATA?


Circle Economy employees are authorised to access personal data only to the extent necessary to serve the applicable purpose and to perform their jobs.


The following third parties have access to your personal data, where relevant, for the provisioning of their products or services to Circle Economy:

  • Banks
  • Insurance companies
  • IT suppliers
  • Accountants


When third parties are given access to your personal data, Circle Economy will take the required contractual, technical and organisational measures to ensure that your personal data are only processed to the extent that such processing is necessary. The third parties will only process your personal data in accordance with applicable law.


If your personal data are transferred to a recipient in a country that does not provide an adequate level of protection for personal data Circle Economy will take measures to ensure that your personal data are adequately protected, such as entering into EU Standard Contractual Clauses with these third parties.


In other cases, your personal data will not be supplied to third parties, except where required by law.


When a third party processes your personal data solely following Circle Economy instructions, it acts as a data processor. We enter into an agreement with such a data processor for the processing of personal data. In this agreement we include obligations to ensure that your personal data are processed by the data processor solely to provide services to us.


HOW ARE YOUR PERSONAL DATA SECURED?


Circle Economy has taken adequate safeguards to ensure the confidentiality and security of your personal data. Circle Economy has implemented appropriate technical, physical and organisational measures to protect personal data against accidental or unlawful destruction or accidental loss, damage, alteration, unauthorised disclosure or access as well as all other forms of unlawful processing (including, but not limited to, unnecessary collection) or further processing. Examples are IT security policies, staff training and secure servers.

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 data, or may need to retain your personal data in order to continue providing a service.

Pursuant to GDPR, users have the following rights regarding their personal data.

Circle Economy acknowledges that you have the right to access your personal data. Upon request Circle Economy will provide you with information about whether we hold any of your personal data. You may access, correct, or request deletion of your personal data by contacting us at info@circle-economy.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 data for their own purpose.

Circle Economy acknowledges that you have the right to correct your personal data. 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 info@circle-economy.com.

Circle Economy acknowledges that you have the right to remove, or request the removal of, content or information they have posted publicly on the Platform. If you would like us to delete your account record in our system, you are able to do so by contacting us at info@circle-economy.com 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. We do not have control over third parties (e.g., Other Users) who may have copied or reposted this information. If you have included personal data 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.

Circle Economy acknowledges that you have the right to restrict processing of personal data. You may, of course, decline to share personal data with the Platform, in which case the Platform will not be able to provide to you some of the features and functionality found on Circle Economy. For example, absent personal data, you cannot post an Idea or Comment.


COOKIES POLICY

We also collect information through the use of cookies. Cookies are small files of information which save and retrieve information about your visit to this website – for example, how you entered our site, how you navigated through the site, and what information was of interest to you.

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 Website to recognize you at a subsequent visit.

Circle Economy stores cookies that are essential in providing the functionalities of the Website. For instance, cookies that support logging in to password-protected pages on the Circle Economy website.

If you do not wish to receive any cookies at all, you may set your browser to refuse cookies altogether. Please note that in that case you may no longer be able to use all the functionalities of the Website.

Non-strictly necessary 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 cookie being placed, these cookies will be blocked.

Please see below a summary the non-strictly necessary cookies that Circle Economy uses.



Cookies

Google Tag Manager and Analytics

Hotjar

Facebook Pixel

Twitter Tags

LinkedIn Insight Tag


Type

Third Party

Third Party

Third Party

Third Party

Third Party


Purpose

Used to analyse website usage and track main sources of traffic to our domain. 

Used to analyse website usage and collect feedback from users.

Used to target and track the performance of social media advertising. 

Used to target and track the performance of social media advertising. 

Used to target and track the performance of social media advertising. 

Only if you have given prior consent, Circle Economy will use Third Party cookies. 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.

Hotjar is a behavior analytics and user feedback service that helps Circle Economy understand the behavior of the Website users and get their feedback through tools such as heatmaps, session recordings, and surveys. You can find more information about Hotjar’s data and privacy policy here.

The Facebook pixel is a product of Facebook, Inc (Facebook) that allows Facebook uses cookies to provide targeted advertising to Circle Economy users and aggregated statistical data to give insight to Circle Economy in the way Users use the Website following adverts. You can find more information about Facebook’s data and privacy policy here.

The Twitter tag is a product of Twitter, Inc (Twitter). Twitter uses cookies to provide targeted advertising to Circle Economy users and aggregated statistical data to give insight to Circle Economy in the way Users use the Website following adverts. You can find more information about Twitter’s data and privacy policy here.

The LinkedIn Insight Tag is a product of LinkedIn Corporation (LinkedIn). LinkedIn uses cookies to provide targeted advertising to Circle Economy users and aggregated statistical data to give insight to Circle Economy in the way Users use the Website following adverts. You can find more information about LinkedIn’s data and privacy policy here.