Privacy Policy
Effective as of May, 5, 2020.
This Privacy Policy describes how CircleView and our subsidiaries and affiliates (collectively "CircleView," "we", “us” or "our") handle personal information that we collect though our websites and other digital properties that link to this Privacy Policy (collectively, the “Service”), through social media, in connection with our marketing and lead generation activities.
CircleView provides services that businesses use to facilitate their own sales and marketing efforts. In some cases we process personal information on behalf of our business customers while providing services to them. For example, some of our business customers use our service to identify and/or qualify sales leads on their behalf subject to contracts that restrict how we can use this information. This Privacy Policy does not cover personal information that we process on behalf of a business customer. If you have concerns about this information, you should direct your concerns to the relevant business. This Privacy Policy does, however, apply to personal information of professionals that we collect on our own accord and share with our clients and business partners for their own direct marketing purposes.
Our websites, products and services are designed for businesses and their representatives. We do not offer products or services for use by individuals for their personal, family or household purposes. Accordingly, we treat all personal information we collect as pertaining to individuals in their capacities as business representatives and not their individual capacities.
Table of Contents
Personal information we collect
How we use your personal information
How we share your personal information
Your choices
Other sites and services
Security
International data transfer
Children
Changes to this Privacy Policy
How to contact us
Notice to European Users
Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:
- Contact data, such as your first and last name, and email and physical addresses.
- Profile data, such as your username and password that you set to establish an online account with us, and any other information that you add to your account profile.
- Communications that we exchange, including when you contact us with questions, feedback, or otherwise.
- Marketing data, such as your preferences for receiving communications about our products and services, and details about how you engage with our communications.
- Other information that we may collect which is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
Third party sources.We obtain personal information from other sources, such as:
- Data providers, such as information services and data licensors that provide professional and other information.
- Public sources, such as social media platforms.
Automatic data collection We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your activity over time on our sites and other sites and online services. This information may include:
- Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, IP address, unique identifiers, the website you visited before browsing to our website, and general location information such as city, state or geographic area.
- Online activity data, such as pages you viewed, how long you spent on a page, navigation paths between pages, information about your activity on a page, access times, and duration of access.
Cookies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our
Cookie Policy.
We use your personal information for the following purposes or as otherwise described at the time we collect it:
Service delivery. We use your personal information to:
- provide, operate and improve the Service and our business;
- establish and maintain your user profile on the Service;
- communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;
- understand your needs and interests, and personalize your experience with the Service and our communications; and
- provide support for the Service, respond to your requests, questions and feedback.
Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect.
We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.
Marketing and advertising. We and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:
- Direct marketing. We may send you CircleView-related or other direct marketing communications as permitted by law, including by email. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
- Interest-based advertising. We may work with third party advertising companies and social media companies that display ads on our Service and other sites. These companies may use cookies and similar technologies to collect information about you (including the device data and online activity data described above) over time across our Service and other sites and services and your interaction with our emails, and use that information to serve online ads that they think will interest you. You can learn more about your choices for limiting interest-based advertising in our Cookie Policy.
Compliance and protection. We may use your personal information to:
- comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
- protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
- audit our internal processes for compliance with legal and contractual requirements and internal policies;
- enforce the terms and conditions that govern the Service; and
- prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection:
Affiliates. Our subsidiaries and other corporate affiliates, for purposes consistent with this Privacy Policy.
Third parties. We may share your personal information with our business customers or business partners for their own direct marketing purposes. If you are a California resident, this sharing may constitute a “sale” of your personal information under the California Consumer Privacy Act. For information on how to opt-out of this sharing, please see the Your Choices section below.
Service providers. Companies and individuals that provide services on our behalf or help us operate the Service or our business, such as hosting, information technology, customer service, email delivery and website analytics.
Advertising partners. Third party advertising companies that collect information about your activity on the Service and other online services to help us advertise our services, and/or use customer lists that we share with them to deliver ads on their platforms to those customers and similar users.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
Business acquirers. Relevant participants in business transactions (or potential transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, CircleView or our affiliates (including, in connection with a bankruptcy or similar proceedings).
Your choices
You have the following choices with respect to your personal information.
Access or update your information. If you have registered for an account with us, you may review and update certain account information by logging into the account. You can also email us at
privacy@circleview.com to request changes to certain of your account information.
Opt-out of marketing or promotional communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by emailing us at
privacy@circleview.com. You may continue to receive service-related and other non-marketing emails, such as those about your account or our ongoing business relations.
Opt-out of sharing with third parties for their marketing purposes. To opt-out of our sharing of your personal information with third parties for their own direct marketing purposes, please contact us at
privacy@circleview.com.
Cookies and interest based advertising. For more information about the cookies we use and your choices for controlling what information cookies and similar technologies collect about you, including for interest-based advertising purposes, see our
Cookie Policy. Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit
http://www.allaboutdnt.com.
Declining to provide information. We need to collect certain personal information to provide certain services. If you do not provide the information requested, we may not be able to provide those services. We will tell you what information you must provide to receive the Service by designating it as required at the time of collection or through other appropriate means.
Other sites and services
\The Service may contain links to websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or other online services that are not associated with us. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.
Security
We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
International data transfer
We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
European Union users should read the important information provided
below about transfer of personal information outside of the European Union.
Children
The Service is not intended for use by children under 18 years of age. If we learn that we have collected personal information from a child under 18 without the consent of the child’s parent or guardian as required by law, we will delete it.
Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service. If required by law, we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through the Service. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.
If you have any questions about this Privacy Policy, please feel free to contact us using one of the following methods:
Email:
privacy@circleview.com Mail: CircleView, 750 B St, Suite 1800, San Diego, CA 92101, Attention: Privacy
Notice to European users
This section applies only to individuals in the European Economic Area and United Kingdom.
Personal information. References to “personal information” in this Privacy Policy are equivalent to “personal data” governed by European data protection legislation.
Controller. CircleView is the controller of your personal information covered by this Privacy Policy for purposes of European data protection legislation.
Legal bases for processing. The legal bases of our processing of your personal information as described in this Privacy Policy will depend on the type of personal information and the specific context in which we process it. However, the legal bases we typically rely on are set out in the table below. We rely on our legitimate interests as our legal basis only where those interests are not overridden by the impact on you (unless we have your consent or our processing is otherwise required or permitted by law). If you have questions about the legal basis of how we process your personal information, contact us at
privacy@circleview.com.
Processing purpose (click link for details) Details regarding each processing purpose listed below are provided in the section above titled “How we use your personal information”. | Legal basis |
Service delivery | Processing is necessary to perform the contract governing our provision of the Service or to take steps that you request prior to signing up for the Service. Where we cannot process your personal data as required to operate the Service on the grounds of contractual necessity, we process your personal information for this purpose based on our legitimate interest in providing you with the Service you access and request. |
Marketing and advertising | Processing is based on your consent where that consent is required by applicable law. Where such consent is not required by applicable law, we process your personal information for these purposes based on our legitimate interests in promoting our business. |
Research and development Compliance and protection | These activities constitute our legitimate interests. |
Compliance with legal obligations | Processing is necessary to comply with our legal obligations. |
Actions we take with your consent | Processing is based on your consent. Where we rely on your consent you have the right to withdraw it any time in the manner indicated when you consent or in the Service. |
Use for new purposes. We may use your personal information for reasons not described in this Privacy Policy where permitted by law and the reason is compatible with the purpose for which we collected it. If we need to use your personal information for an unrelated purpose, we will notify you and explain the applicable legal basis.
Sensitive personal information
We ask that you not provide us with any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Service, or otherwise to us. If you do not consent to our processing and use of such sensitive personal information, you must not submit such sensitive personal information through our Service.
Retention We retain personal information where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested; to comply with applicable legal, tax or accounting requirements; to establish or defend legal claims; or for fraud prevention). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Your rights European data protection laws give you certain rights regarding your personal information. If you are located within the Europe, you may ask us to take the following actions in relation to your personal information that we hold:
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information.
- Transfer. Transfer a machine-readable copy of your personal information to you or a third party of your choice.
- Restrict. Restrict the processing of your personal information.
- Object. Object to our reliance on our legitimate interests as the basis of our processing of your personal information that impacts your rights.
You may submit these requests by email to privacy@circleview.com or our postal address provided above in the How to contact us section. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or our response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator here.
Cross-Border Data TransferIf we transfer your personal information from Europe to a country such that we are required to apply additional safeguards to your personal information under European data protection laws, we will do so. Please contact us for further information about any such transfers or the specific safeguards applied.