EFFECTIVE DATE: MAY 21, 2024

This Privacy Policy tells you how Circle of XYZ, Inc. (“we,” “us,” “our”) collects, uses and shares information we collect on our website www.thisiscircleof.com (“Site”) effective as of the date posted above. By using the Site and submitting information you agree that we may use and disclose your information according to the terms of this Policy.

Information we collect

We collect information when you visit our Site, including information you provide, information we receive from other sources and information that we automatically collect (as discussed below). We retain information for as long as it is relevant to our business and as required by law.

“Personal Information” is information that, directly or indirectly, identifies you or another individual and which may include: name, postal/email address, telephone number, date of birth, gender, payment information, browser and device information (including Internet Protocol (IP) address), and information collected through cookies and other similar technologies. If you submit any Personal Information relating to other people to us or to our service providers in connection with the Site, you represent that you have the authority to do so, have provided a copy of this Privacy Policy to the relevant individual, and that they permit us to use the information in accordance with this Privacy Policy.

Information you provide

We collect information that you submit when visiting the Site including registration information (your name, email or postal address, telephone number, date of birth, gender, and user name and password), and contact information if you contact us with an inquiry (email address, telephone number). Payment card information is collected by our third-party payment processor if you make a purchase (name, billing and shipping address, card information, email and telephone number). You may also submit additional information about yourself when you use the Site, but such additional information is not required in order to use our services.

Information we receive from third parties

We use a third-party payments processor to receive your information and process your payments; we may receive some information from the processor, such as the fact that you made a payment but not the credit card number that you used for that payment.

How We Use This Information

We use this information to facilitate the provision of your requested services, improve our products and services, to grow our business, for our own research and to comply with our legal obligations. We use your contact information to respond to your inquiries or to provide information on our services to you.

Sharing Your Information

We do not sell your personal information for commercial purposes. We may share your information with third-party service providers that help us run the Services or to facilitate the products and services you obtain from us. We may share your information to monitor or improve our Services. We may also share information with third parties in limited circumstances, such as complying with legal processes, cooperating with law enforcement, preventing fraud or imminent harm, ensuring the security of our network and services, when we believe your actions violate our Terms of Service, or in the event we are transferred or sold to another entity as a result of a corporate sale, merger, consolidation, asset sale, or in the unlikely event of bankruptcy.

Third Parties

Your information may be held by third parties or we may link to other sites or applications not affiliated, owned, or controlled by us. Further, we may use products and services of third parties, for which the disclosure of your information is necessary, to help us better provide our Services to you. We expressly disclaim any and all liability for the actions of third parties. The privacy practices of any third parties are outside the scope of this Privacy Policy and their use or disclosure of your information (including your personal information) will be governed by their own privacy practices or policies. We encourage you to review the privacy practices or policies of those third parties.

Your Rights

If you would like to access, modify, or delete your personal information, you may submit a request to [email protected] California residents may have additional personal information rights. For more information or to see if these rights apply to you, please contact us. We will promptly review all such requests in accordance with applicable laws. 

Rights for Persons Covered by GDPR

If you are “data subject” for whom the processing of personal information is subject to REGULATION (EU) 2016/679 (GDPR) (“Covered Person”), the rights described in sections (A) through (G) apply to you.

1. Right of access, rectification, erasure and restriction of processing: you may obtain access to your personal information stored by us by contacting us. If we process or use your personal information, we shall endeavor to ensure, by implementing suitable measures, that your personal information is accurate and up to date for the purposes for which they were collected. If your personal information is inaccurate or incomplete, you may obtain the rectification of such personal information by contacting us. You may obtain the erasure or restriction of processing of your personal information in situations where no legitimate business purpose exists or the further storage is unnecessary under statutory storage obligations.
2. Right to data portability: you may receive the personal information about you that you have provided to us, in a structured, commonly used and machine-readable format or transmit this information to another controller. To exercise this right, contact us.
3. Right to object: you may object, on grounds relating to your particular situation, to the processing of your personal information. To exercise this right, you must contact us as provided herein. To the extent your personal information is processed for reasons other than direct marketing, you understand and agree that we have compelling legitimate reasons for information processing, such as providing access to our Services. You may use ad-blocking software to limit information capture and usage. You may also contact us with questions about this policy or to make a removal request. Making a request does not guarantee that the request will be honored.

1. Right to withdraw your consent: If you have given your consent to the collection or processing of your personal information, you may withdraw your consent without affecting the lawfulness of processing based on consent before its withdrawal by contacting us in writing.
2. We currently store your personal information in the United States, but your personal information may be transferred stored, or processed in a location outside of the United States.
3. If you make a request under sections (A) – (D), above, we have 30 days to respond to you. To exercise any of these rights, please contact us.
4. The legal basis for processing your personal information is:
5. You have given us consent by agreeing to abide by our Privacy Policy and Terms of Service and continuing to access the Services; and
6. Processing is necessary in order for us to comply with legal obligations.

Children’s Online Privacy Protection Act

The Services are intended for general audiences and are not directed to children under 13 years old. We do not target the Services to children under 13, and we do not intentionally collect any information from users under 13. If you become aware that your child has used the Services, and we may have personal information about a user under 13, please contact us at [email protected], so we may delete the information.

Cookies

Cookies are small bits of electronic information that a website or application sends to your browser and are stored on your hard drive. We use cookies to identify users, keep the Services secure, and improve the Services’ performance. Cookies are not required to browse our Services and may be disabled or deleted. Third parties may employ cookies on the Services in order to better perform their services. We have no control over third-party cookies, and therefore, disclaim any and all liability related to third-party cookies.

Changes and Updates to Privacy Policy

This Privacy Policy may be revised periodically, and this will be reflected by the date above. Please revisit this page to stay aware of any changes. Your continued use of the Services constitutes your agreement to this Privacy Policy and any future revisions.

Contact Information

If you have any questions or concerns about this Privacy Policy, please email us at [email protected]