Connected Circles Privacy Policy

Connected Circles BV ("Connected Circles",” “we,” “our,” or “us”) is committed to protecting your privacy. We want you to be confident in the knowledge that we treat your personal information with care and in accordance with our obligations under applicable data protection and privacy laws. This privacy policy (“Policy”) describes how we obtain and process your personal information when we provide you with our services and when you use our services, all herein referred to as the “Services”.

This Policy governs how Connected Circles handles personal information you provide to us, subject to notice or consent where required by applicable law.

This Policy applies to all clients of Connected Circles. It also applies to any visitors to our websites, who may or may not be clients of Connected Circles.

Our Services may contain links to other companies’ websites and services which they offer; these companies may have privacy policies of their own. We recommend that you read the privacy policies of such third parties. We are not responsible for the privacy practices or content of any such third parties’ products or third parties’ services.

By providing us with your personal information or otherwise using our Services, you acknowledge that you have read, understood, and agree to the terms of this Policy.

Information we collect

We collect the following information:

Personal information such as your name, gender, date of birth, relationships, occupation, employment, education, and social life details.
Contact and account information such as your addresses, telephone numbers, email addresses, username, and any other contact and/or account information that you provide us.
Sensory information such as photos and videos of you and audio recordings of phone calls between you and us, where permitted by law.
Social media. When you engage Connected Circles to provide the Services, you will be required to provide the following information from your social media accounts: login details, password.
Third-party social media accounts. By providing us with the social media account details of any third party, you are agreeing and acknowledging that you have the express right and authority to do so on their behalf.
Publicly available information we receive from social networking websites or other third parties. When you engage Connected Circles to provide the Services through various social media networks, we may receive information from the social network including your profile information, profile picture, profile name, the user ID associated with your social media account, country, and any other information you permit the social network to share with third parties. Depending on your social media activity and depending on what information you chose to post, we may also receive sensitive information such as physical and mental health details, sexual life, racial or ethnic origin, religion. The data we receive is dependent upon your privacy settings with the social network, and we will not post information about you on third party social media sites without your consent. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before engaging with our Services.
Other. Other information you provide to us when you use our Services or otherwise interact with us.

By providing personal information to Connected Circles you explicitly agree that the information you provide is current, accurate and that you will update it if there are any changes. You are responsible for any third-party personal information obtained, published, or shared by you through Connected Circles and hereby confirm that you have the third party's consent to provide the personal information to Connected Circles.

We may use your personal information to communicate with you. You may choose how you would like to receive information from us. Options include mail, email, telephone, or text. If you send us an email or request information we will retain your email address and use it to respond to your inquiry. With your permission, we may contact you from time to time with communications that we feel will be of interest to you such as information about our Services, news, updates, and promotions. We may also use your email address to provide you with details on upcoming events and other information about Connected Circles or to provide you with information from companies with whom we have cooperative or joint marketing arrangements.

Why do we collect your information?

Connected Circles may process your personal information if one of the following applies:

You have given your consent for one or more specific purposes.
Provision of personal information is necessary for the performance of an agreement and/or for any pre-contractual obligations thereof.
Processing is necessary for compliance with a legal obligation to which Connected Circles is subject.
Processing is necessary for the purposes of the legitimate interests pursued by Connected Circles or by a third party.
To comply with laws and regulations that apply to us.

Who do we share your information with?

We may share your information with our affiliated companies and third parties in certain circumstances. We will reveal certain personal information described in this Policy to unaffiliated third parties only if: (i) you request or authorize it; (ii) the information is provided to help complete a transaction for you; (iii) the information is provided to comply with the law, applicable regulations, governmental and quasi-governmental requests, court orders or subpoenas, to enforce our legal notices or other agreements, or to protect our rights, property or safety or the rights, property or safety of our clients or others; (iv) the disclosure is done as part of a purchase, transfer or sale of services or assets.

We may also anonymize or aggregate data about you and disclose such anonymized or aggregated information to third parties for promotional or other purposes.

We limit the number of our employees who have access to personal information to a select group of specially authorized employees. Access is granted to these employees for the proper performance of their duties on a need to know basis.

How do we protect your personal information?

We work very hard to protect your privacy and have taken key steps in protecting it. We have implemented solutions to protect personal information, which consist of a variety of both technical and policy-based solutions which vary depending on the applicable Service provided to you. These solutions may include, but are not limited to, password protection, encryption, firewalls, anti-virus, intrusion detection, anomaly detection, and access controls for our employees.

How long and where do we keep personal information?

We must keep personal information for no longer than is necessary for us to fulfill the purposes for which the personal information was collected unless we are specifically required to keep your personal information longer by applicable law. The retention period of the personal information differs for the various categories. Personal information of our clients is stored in Europe for which appropriate security safeguards are in place. If you wish to enquire further about these appropriate safeguards, please contact us using the details set out below.

For clients in the EU, UK, and Switzerland

If you reside in the EU, UK, or Switzerland, you are entitled to the following rights in respect of the personal information that we hold:

Withdraw your consent at any time. You have the right to withdraw your consent where you have previously given your consent to the processing of your personal information.
Object to processing of your information. You have the right to object to the processing of your personal information if the processing is carried out on a legal basis other than consent. Further details are provided in the dedicated section above.
Access your personal information. You have the right to learn if your personal information is being processed by Connected Circles, obtain disclosure regarding certain aspects of the processing, and obtain a copy of the information undergoing processing.
Verify and seek rectification. You have the right to verify the accuracy of your personal information and ask for it to be updated or corrected.
Restrict the processing. You have the right, under certain circumstances, to restrict the processing of your personal information. In this case, Connected Circles will not process your personal information for any purpose other than storing it.
Have personal information deleted or otherwise removed. You have the right, under certain circumstances, to obtain the erasure of your information from Connected Circles.
Receive information and have it transferred to another controller. You have the right to receive your personal information in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the personal information is processed by automated means and that the processing is based on your consent, on a contract which you are part of, or on pre-contractual obligations thereof.
Lodge a complaint. You have the right to bring a claim before the competent data protection authority.

How to exercise your rights?

If you wish to exercise your privacy rights, please contact us at privacy@connectedcircles.net

Changes to this Policy

Please read this Policy in conjunction with any terms and conditions that may apply to the Services that you have signed up for. This Policy may be subject to change from time to time. We will proactively inform you about such change, by providing you a summary of the change through e.g. email together with a link to the new version of this Policy on our websites.

Contact

If you have any questions, comments, or complaints regarding this Policy, you can write to us at the following address Attn. Data Privacy, Connected Circles B.V., Keizersgracht 590-M, 1017 EN Amsterdam, The Netherlands or contact us via email: privacy@connectedcircles.net

Effective date: 1 December 2020