Summary of Major Changes
Our Commitment to Privacy
Types of Information We Collect
When you interact with us through the Site or the Services, we may collect Personal Data and other non-personal information from you, as further described below.
Personal Data That You Provide Through the Site: Personal Data is information that identifies you and that can be used alone to contact you online or offline. We collect Personal Data from you when you provide such information to us such as when you register for access to the Services (for example, contact information such as your name, email address, and mailing address) when you wish to use certain Services (for example financial information such as bank account numbers, your date of birth and the last four digits of you social security number), when you contact us with inquiries or respond to our marketing surveys and email campaigns, when you link to your profile on a third-party site or platform with your Account, and otherwise when you use our services where Personal Data is required for use and/or participation. When anonymous information is directly associated with Personal Data, this anonymous information is also treated as Personal Data.
Non-Personal, Anonymous, or Aggregated Data: Non-personal information, alone, cannot be used to identify or contact you. When you interact with CircleUp through the Site or Services, we receive and store certain non-personal information about you for purposes that include improving our products and services, troubleshooting bugs, providing services to you, facilitating the provision of updates, dynamically served content and product support, and communicating with you. Such information, which may be collected passively using various technologies or through other means, may include demographic information including gender, age, zip code, information about your computer, hardware, software, media, mobile device, including unique device IDs or other device identifiers, incident data, Internet Protocol (IP) address, network Media Access Control (MAC) address and connection. We may also receive information from third parties in connection with marketing and demographic studies and/or other data that we use to supplement personal information provided directly by you.
How We Collect Information
We collect information you provide to us when you request products, services or information from us, register with us, participate in forums or other activities in our sites and applications, respond to surveys or otherwise interact with us.
In order to access additional functionality of the Site, you may be required to create an account for your use of the Service (an “Account”). You may create an Account directly via the Site or by logging into your Account with certain third party social networking sites (including Facebook and LinkedIn) via our Service. If you decide to create an Account by logging into a social networking site via our Service, we will obtain the Personal Data you have provided to the social networking site (such as your name, profile picture, email address, and other information you make publicly available via the applicable social networking site) from the account you have with such social networking site and use that information to create your Account. The information we obtain may depend on the privacy settings you have with the social networking site. We also collect other information that you provide as part of account registration and your use of the Service.
- Internet Log Files
As is true of most web sites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. CircleUp may store such information itself or such information may be included in databases owned and maintained by CircleUp affiliates, agents, or service providers. This Site may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, the domain names of our visitors' Internet service providers, and how our users use and interact with the Services. Also, in an ongoing effort to better understand and serve the users of the Services, CircleUp often conducts research on its customer demographics, interests, and behavior based on Personal Data and other information provided to CircleUp by Issuers and Users.
This research may be compiled and analyzed on an aggregate and non-aggregate basis. CircleUp may share this data, including Personal Data, with its affiliates, agents and business partners. CircleUp may also disclose such user statistics in order to describe our Services to current and prospective business partners and to other third parties for other lawful purposes.
- Clear GIFs and Tracking Pixels
Clear GIFs (including web bugs, beacons or tags) are small graphic images placed on a web page, web-based document, or in an email message. Clear GIFs are invisible to the user because they are small (only 1-by-1 pixel) and usually the same color as the background of the web page, document or email message. We use clear GIFs to collect your Personal Data. Furthermore, we use clear GIFs to capture statistical usage information for our web pages, features or other elements on a web page. We correlate this information to a user to personalize user experience and for statistical analysis of user experiences on our web pages.
We and third parties may also use tracking pixels, which allow us to advertise more efficiently by, for example, excluding our current users from certain promotional messages or identifying the source of a new installation.
- Analytic Metric Tools and Other Technology
CircleUp uses third party analytics technologies to collect information when you use our online services. These tools and technologies use server log files, web beacons, cookies, tracking pixels and other technologies to collect and analyze certain types of information, including cookies, IP addresses (including for purposes of determining your approximate geographic location), mobile or other hardware device ID or other device identifiers, browser types, browser language, information passed from your browser (if any), referring and exit pages, and URLs, platform type, click information, information about your media, peripheral hardware, software and/or applications installed on your machine and/or device, domain names and types, landing pages, pages viewed and the order of those pages, advertising conversion rates, the date and amount of time spent on particular pages, other internet and website usage information, and the date and time of activity on our websites, as well as unique hardware identifies such as MAC Address, mobile unique device ID (if applicable) and other similar information.
The third party analytics companies who collect information on our sites and in the context of our products and/or services may combine the information collected with other information they have independently collected from other websites and/or other online or mobile products and services relating to your activities across their network of websites as well as online and/or mobile products and services. Many of these companies collect and use information under their own privacy policies.
- This Site Uses Google Analytics and AdWords
- Ad Serving Technology
The advertising companies who deliver ads for us may combine the information collected or obtained from CircleUp with other information they have independently collected from other websites and/or other online or mobile products and services relating to your web browser’s activities across their network of websites. Many of these companies collect and use information under their own privacy policies.
For more information about the practices of other ad serving companies that may collect information based on your interaction with ads on this site, in our mobile products, and other sites or products not owned/managed by CircleUp, or to “opt out” of targeted advertising delivered by National Advertising Initiative (NAI) member ad networks, you should visit www.networkadvertising.org.
- Other Information Collected From Third Parties
CircleUp may also receive other information from third parties, including in connection with the operation of our products and services as well as marketing and demographic studies that we use to supplement personal and anonymous information or provided directly by you. Some third party services such as Twitter, Facebook, and LinkedIn may also provide us with information from your accounts there with your permission.
CircleUp may also collect or receive information about you from other CircleUp users who choose to upload their email and other contacts. This information will be stored by us and used primarily to help you and your friends connect
Our Use of Your Personal Data and Other Information
If you choose to use our service to refer a friend to a CircleUp product or site, we may ask you for your friend’s name and email address. In such cases, we will send your friend an email on your behalf inviting him or her to visit the site or check out our products. CircleUp retains your friend’s name and email for a short period for the sole purpose of sending this email. We do not keep or use this information for any other purpose.
Our Disclosure of Your Personal Data and Other Information
From time to time, CircleUp employs third party contractors to collect Personal Data on our behalf to provide email delivery, products, promotional fulfillment, shipping or other services on our sites. When requesting these services, you may be asked to supply your name, mailing address, telephone number and email address to our contractors. We ask some third party contractors, such as data analytics or market research firms, to supplement personal information that you provide to us for our own marketing and demographic studies, so that we can consistently improve our sites and related advertising to better meet our visitors’ needs and preferences. To enrich our understanding of individual customers, we tie this information to the Personal Data you provide to us.
You will be notified before your Personal Data is collected by any third party that is not our agent/service provider, so you can make an informed choice as to whether or not to share your information with that party.
We may also access and disclose personal information, including personal communications, in connection with report abuse functions in our products and services, to enforce legal rights and comply with the law, or to comply with an order from a government entity or other competent authority, or when we have reason to believe that a disclosure is necessary to address potential or actual injury or interference with our rights, property, operations, users or others who may be harmed or may suffer loss or damage, or when we believe that disclosure is necessary to protect our rights, combat fraud and/or comply with a judicial proceeding, court order, or legal process served on CircleUp. Note that certain publicly available information you post and communicate on our and third party sites and services is public information for which you have no expectation of privacy.
We display personal testimonials of satisfied customers on our site in addition to other endorsements. With your consent we may post your testimonial along with your name and other information. If you wish to update or delete your testimonial, please contact us at firstname.lastname@example.org
- Public Information Including User Generated Content, Forums, Blogs, And Profiles
Our Web site offers a publicly accessible blog. You should be aware that any information you provide in this area may be read, collected, and used by others who access them. To request removal of your personal information from our blog, contact us at email@example.com. In some cases, we may not be able to remove your Personal Data, in which case we will let you know if we are unable to do so for any reason.
You may choose to disclose information about yourself in the course of contributing content to CircleUp or in our online forums, blogs, message boards, user “profiles” for public view or in similar forums on our sites and/or on third party sites. Information that you disclose in any of these forums is unencrypted, public information, may be accessed or recorded by CircleUp employees, and there is no expectation of privacy or confidentiality there.
You should be aware that any Personal Data you submit in the course of these public activities can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the Personal Data you choose to make public in any of these forums.
Note also that in the ordinary course of Internet activity, certain information may be sent from your browser to third parties such as advertising networks and analytics companies. CircleUp has no control over the information sent from your browser to those networks or other third parties and recommends that you ensure that your browser settings prevent the disclosure of information you would not like to share.
If you post a video, image, or photo on one of our sites for public view should you be aware that these may be viewed, collected, copied and/or used by other users without your consent. We are not responsible for the videos, images, or photos that you choose to submit to the CircleUp site.
There are also certain circumstances in which we may share your Personal Data and other information with certain third parties without further notice to you, as set forth below:
Business Transfers:As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets and you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.
Agents, Consultants and Related Third Parties:CircleUp, like many businesses, sometimes hires other companies to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases, ID verification, processing applications, shipping and fulfillment, and processing payments and completing transactions. When we employ another company to perform a function of this nature, we only provide them with the information that they need to perform their specific function. These companies are authorized to use your personal information only as necessary to provide these services to us.
Legal Requirements:CircleUp may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of CircleUp, (iii) act in urgent circumstances to protect the personal safety of users of the Site or the public against fraud or other harm, or (iv) protect against legal liability.
Your Controls and Choices
When you sign up for our Services or newsletter(s), we will send periodic emails to you regarding the Services or to tell you about services we believe will be of interest to you. Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or you can contact us at firstname.lastname@example.org.
Data Security, Integrity and Retention
The security, integrity and confidentiality of your information are important to us. We use commercially reasonable efforts to follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. When you enter sensitive information (such as bank account information) on our website, we encrypt the transmission of that information using secure socket layer technology (SSL). We also use third party ID verification to ensure our users’ true identities are validated. From time to time, we review our security procedures to consider appropriate new technology and methods. Please be aware, however, that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee that your information will not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. We cannot assume responsibility or liability for unauthorized access to our servers and systems. We will retain your information for as long as your Account is active or as needed to provide you services unless a longer retention period is required or permitted by law. If you wish to cancel your Account or request that we no longer use your information please contact us at email@example.com If have any questions about security on our Web site, you can also contact us at firstname.lastname@example.org as well.
Links to Other Web Sites
California Residents: California Privacy Rights
Under California law, California Residents who have an established business relationship with CircleUp or one of its subsidiaries may choose to opt out of CircleUp’s disclosure of Personal Data about them to third parties for direct marketing purposes. If you choose to opt out at any time after granting approval, email email@example.com or write to CircleUp Network Inc., 30 Maiden Lane, Floor 6, San Francisco, CA, 94108.
CircleUp Network, Inc.
CircleUp Network Inc.
30 Maiden Lane, Floor 6
San Francisco, CA 94108