Important information and who we are
1.1. In this Privacy Statement, Circlegain Ltd. (“Circlegain”) explains which (personal) data Circlegain collects and how Circlegain uses and protects your (personal) data. Circlegain is responsible for ensuring that it uses that Personal Data in compliance with data protection laws.
1.4 This website is not intended for children and we do not knowingly collect data relating to children.
The products and services we provide
The types of personal data we collect and storage time
3.1. In order to respond to your request submitted through the contact form, we will collect and process the following Personal Data about you: your first name, last name, e-mail address, phone number. The nature of the services you are requesting will determine the kind of Personal Data we might ask for, though such information may include (by way of a non-exhaustive list): name of current employer and job title; and any details that may be relevant in relation to your request.
3.2. In order to receive our newsletter, you may submit your e-mail address, first name, last name, phone number via Get in Touch form.
3.3 In order to answer career applications. For further information how personal data of applicants and employees of Circlegain are processed, we kindly refer to the privacy policies we provide to these applicants and employees.
3.5 Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
3.6 We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.Contact Data includes billing address, delivery address, email address and telephone numbers.Financial Data includes bank account and payment card details.Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website. Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses. Usage Data includes information about how you use our website, products and services. Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
3.8 We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
3.9 If you fail to provide personal data where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
How do we collect your data?
We use different methods to collect data from and about you including through:Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you: apply for our products or services; create an account on our website; subscribe to our service or publications; request marketing to be sent to you; enter a competition, promotion or survey; or give us feedback or contact us.Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:Technical Data from the following parties: analytics providers; advertising networks; and search information providers; Contact, Financial and Transaction Data from providers of technical, payment and delivery services; Identity and Contact Data from data brokers or aggregators; Identity and Contact Data from publicly available sources.
5. How we use your information
5.1. Your Personal Data may be stored and processed by us in the following ways and for the following purposes: for the purpose of replying to your requests via get in touch form Website; to communicate with you in order to provide you with services or information about Circlegain; for ongoing review and improvement of the information provided on Website to ensure they are user friendly and to prevent any potential disruptions or cyber attacks; to allow you to use and access the functionality provided by Circlegain; for statistical monitoring and analysis of current attacks on devices and systems; for in-depth threat analysis; to understand your needs and interests; in order to comply with and in order to assess compliance with applicable laws, rules and regulations, and internal policies and procedures; or for the administration and maintenance of databases storing Personal Data.In case of explicit consent via Get in touch form, your Personal Data will be used for marketing communication regarding existing or new Circlegain services.
5.2. However we use Personal Data we make sure that the usage complies with the law and the law allows us and requires us to use Personal Data for a variety of reasons. These include: we need to do so in order to perform its contractual obligations with its customers; we have obtained your consent; we have legal and regulatory obligations that we have to discharge; we may need to do so in order to establish, exercise or defend our legal rights or for the purpose of legal proceedings; the use of your Personal Data as described is necessary for our legitimate business interests, such as:- allowing us to effectively and efficiently manage and administer the operation of our business;- maintaining compliance with internal policies and procedures;- monitoring the use of our copyrighted materials; and- enabling quick and easy access to information on Circlegain.
6. Disclosure of your information to the third parties
6.1. We may share your Personal Data within Circlegain and any of its group companies for the purposes described above:
6.2. We may also share your Personal Data outside of the Circlegain group for the following purposes: with third party agents and contractors for the purposes of providing services to us. This will include Circlegain’s accountants, professional advisors, IT and communications providers and debt collectors as well as companies that provide CMS, hosting and backup services, sales and support services to Circlegain. In such a case, Circlegain ensures, by way of contracting with these companies, that your (personal) data will not be used for other purposes, while we also ensure that your (personal) data will be removed once they are no longer needed.to the extent required by law, for example if we are under a duty to disclose yourPersonal Data in order to comply with any legal obligation (including, without limitation, in order to comply with tax reporting requirements and disclosures to regulators), or to establish, exercise or defend its legal rights; if we sell our business or assets, in which case we may need to disclose your PersonalData to the prospective buyer for due diligence purposes; and if we are acquired by a third party, in which case the Personal Data held by us about you will be disclosed to the third party buyer.
6.3. We will ensure that each third party we share Personal Data with will be subject to appropriate data protection obligations.7. International transfers of your personal data
7.1. Circlegain is a global business. Our customers and our operations are spread around the world. As a result we collect and transfer Personal Data on a global basis. That means that we may transfer your Personal Data to locations outside of your Country.
7.2. Where we transfer your Personal Data to another country outside the EEA, we will ensure that it is protected and transferred in a manner consistent with legal requirements. In relation to data being transferred outside of Europe, for example, this may be done in one of the following ways: the country that we send the data to might be approved by the European Commission as offering an adequate level of protection for Personal Data; the recipient might have signed up to a contract based on “model contractual clauses” approved by the European Commission, obliging them to protect your Personal Data; where the recipient is located in the US, it might be a certified member of the EU-US Privacy Shield scheme; orIn other circumstances the law may permit us to otherwise transfer your Personal Data outside Europe.
7.3. You can obtain more details of the protection given to your Personal Data when it is transferred outside Europe (including a copy of the standard data protection clauses which we have entered into with recipients of your Personal Data) by contacting us as described in paragraph 11 below.
8. How we safeguard your information
8.1. We have extensive controls in place to maintain the security of our information and information systems. Client files are protected with safeguards according to the sensitivity of the relevant information. Appropriate controls (such as restricted access) are placed on our computer systems. Physical access to areas where Personal Data is gathered, processed or stored is limited to authorised employees.
8.2. As a condition of employment, Circlegain employees are required to follow all applicable laws and regulations, including in relation to data protection law. Access to sensitive Personal Data is limited to those employees who needs it to perform their roles. Unauthorised use or disclosure of confidential client information by Circlegain employees is prohibited and may result in disciplinary measures.
9. How long we keep your personal information
9.1. How long we will hold your Personal Data for will vary and will be determined by the following criteria: the purpose for which we are using it – Circlegain will need to keep the data for as long as is necessary for that purpose; and legal obligations – laws or regulation may set a minimum period for which we have to keep your Personal Data.
10. Your rights
10.1. In all the above cases in which we collect, use or store your Personal Data, you may have the following rights and, in most cases, you can exercise them free of charge.
These rights include: the right to obtain information regarding the processing of your Personal Data and access to the Personal Data which we hold about you; the right to withdraw your consent to the processing of your Personal Data at any time. Please note, however, that we may still be entitled to process your Personal Data if we have another legitimate reason for doing so. For example, we may need to retain Personal Data to comply with a legal obligation; in some circumstances, the right to receive some Personal Data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to Personal Data which you have provided directly to Circlegain; the right to request that we rectify your Personal Data if it is inaccurate or incomplete; the right to request that we erase your Personal Data in certain circumstances. Please note that there may be circumstances where you ask us to erase your Personal Data but we are legally entitled to retain it; the right to object to, or request that we restrict, our processing of your Personal Data in certain circumstances. Again, there may be circumstances where you object to, or ask us to restrict, our processing of your Personal Data but we are legally entitled to refuse that request; and the right to lodge a complaint with the relevant data protection regulator if you think that any of your rights have been infringed by us.
10.2. You can exercise your rights by contacting us using the details listed in paragraph 11 below.
11. Designated representatives
11.1. Circlegain’s registered office may be contacted using the following contact Information: info@
11.2. Circlegain’s designated representative in the EU may be contacted using the following contact information: info@
12.1. If you have any questions or concerns about Circlegain’s handling of your Personal Data, or about this Policy, please contact our Privacy Officer using the following contact information: info@
We are usually able to resolve privacy questions or concerns promptly and effectively. If you are not satisfied with the response you receive from our Privacy Officer, you may escalate concerns to the applicable privacy regulator in your jurisdiction. Upon request, Circlegains’ Privacy Officer will provide you with the contact information for that regulator.