Circle Strategies User Privacy Notice

Last Updated: July, 23, 2024

This Privacy Notice describes how People Center, Inc. d/b/a Circle Strategies and its affiliates (collectively “ Circle Strategies ”, “ we ”, “ us ”, and/or “our”) collect and process your personal information for our purposes when you interact with Circle Strategies websites, services, content, and any related software, mobile applications, and other applications (collectively, “ Services ”).

When you access or use our Services, you acknowledge that you have read this Privacy Notice and understand its contents. Your use of our Services and any dispute over privacy is subject to this Privacy Notice.

In connection with the provision of specific Services, we may provide additional “just-in-time” disclosures or additional information about our data processing practices. These notices may supplement this Privacy Notice, clarify Circle Strategies’ privacy practices in the circumstances described or may provide you with additional choices about how Circle Strategies processes your personal information.

1. What This Privacy Notice Covers

This Privacy Notice applies to the personal information we collect and process, when you:

• visit, interact with, or use any Circle Strategies website, and/or Circle Strategies Services;
• create or administer your Circle Strategies account;
• receive communications from, or otherwise interact or communicate with us, including via email, phone, or mail, or using our branded social media pages;
• register or take part in our marketing, learning, or training events; and
• offer or integrate your application, content, product, or services on or through Circle Strategies Services.

This Privacy Notice does not apply to the following.

Customer Personal Data.  Customer Personal Data is any personal data that you submit to us for processing to provide the Circle Strategies Services, such as when you provide your bank account information for payroll processing, or demographic information for benefits enrollment purposes. Customer Data does not include the account information about you that you provide to us in connection with the creation or administration of your Circle Strategies account.

Circle Strategies as an employer.  Any personal information we collect or process in our capacity as an employer, co-employer, or employer of record.

Third party data.  Any products, services, websites or content that are offered by third parties through integrations with Circle Strategies Services, which are governed by their own respective privacy policies.

Circle Strategies also creates and uses de-identified data in some instances, as well as combines personal data with non-personal data (such as company-level information). We either maintain such data without attempting to re-identify it, or treat such data as personal data subject to applicable law.

 

2. Personal Information We Collect

The personal information we collect depends on the context of your interactions with Circle Strategies and the choices you make, the Services and features you use, your location, and applicable laws, but can include the following:

Information You Provide To Us: We collect any information you provide us when you interact with us, such as when you complete a form on our website to obtain additional information about our Services. This information may vary depending on how you interact and what you choose to share with us, and includes:

Business contact information: Such as your name, address, phone number, and email address.

Current employment information: Such as your company name, job title, job level, team/department, and start date.

Account information: Such as credit card and bank account information, VAT numbers and other tax identifiers that you use to pay for Circle Strategies Services, usernames, and other authentication and security credential information.

Identification: Such as government-issued identification documents to comply with global anti-money laundering (AML) and know your customer (KYC) obligations.

Call and video recordings: We may record sales and implementation phone calls, video calls, teleconferences, and web conferences (including audio and video content) to the extent permitted by applicable law. We will always notify you before a call is recorded and will obtain your consent where required under applicable law.

Location Information: Certain Services may request permission to access your location. Where you grant this permission, we will collect information about your location using GPS, wireless, or Bluetooth technology. You can control access to precise location information through your mobile device settings.

Vendor information: To onboard new partners or vendors to Circle Strategies Services, we may collect certain information such as your Tax Identification Number (TIN) or other tax documents, information contained in invoices you have issued, and financial information (such as your bank account number).

Other information: Such as when you fill in a form on our website, respond to surveys, provide feedback, make a support inquiry, participate in promotions, or otherwise communicate with us. Providing your personal information is optional, but it may be necessary for certain Services, such as account registration. In such cases, if you do not provide your personal information, we may not be able to provide you with the requested Services.

Information We Collect Automatically: We automatically collect certain types of information when you interact with our Services, such as when you visit our website or what web pages you visit. We use common information gathering tools, such as tools for collecting usage data, cookies, web beacons and similar technologies to automatically collect information that may contain personal information from your computer or mobile device as you navigate our Services or interact with emails we have sent you. This information includes:

Usage and interaction information: The full Uniform Resource Locators (URL) clickstream to, through, and from our website (including date and time) and Services, content you viewed or searched for, page response times, download errors, length of visits to certain pages, and page interaction information (such as scrolling, clicks, and mouse-overs).

Log data and device Information: Such as IP address, information about your Internet service provider, computer and device information including device, application, or browser type and version, browser plug-in type and version, operating system, or time zone setting, authentication and security credential information, access dates and times, occurrences of technical errors, diagnostic reports, your settings preferences, backup information, API calls, and other logs.

Information We Collect from Other Sources: We collect information about you from other sources, including partners from whom we receive demographic and business contact information, or who provide us with publicly available information that may contain personal information, as well as customers from whom we receive vendor information. We may combine this information with the personal information that you provide. This information may include marketing, sales generation, and recruitment information such as your name, email address, physical address, phone number, and similar contact information.

If you are the administrator for your organization or a vendor, this may also include personal information necessary to verify your identity and prevent fraud, such as your name, address, phone number, banking details, Social Security Number, and IP address.

If you are a vendor, we may also receive from our customers your TIN or other tax documents, information contained in invoices you have issued, and financial information (such as your bank account number) in connection with facilitating bill payments on behalf of our customers.

 

3. How We Use Your Personal Information

Our purposes for using personal information include:

Providing Circle Strategies Services: We use your personal information to provide and deliver our Services and process transactions related to our Services, including registrations, purchases, and payments.

Communicating with you: We use your personal information to communicate with you about our Services via different channels (e.g., by phone or email) and to respond to your requests.

Measuring, troubleshooting, and improving our Services: We use your personal information to provide, maintain, improve, and develop our Services, including by measuring their use, analyzing their performance, and fixing errors.

Recommendations and personalization: We use your personal information to recommend Circle Strategies Services that might be of interest to you, identify your preferences, and personalize your experience with Circle Strategies Services.

Advertising and marketing: We use your personal information to send you promotional messages, marketing, advertising, and other information based on your preferences, and to personalize, measure, and improve our advertising. We may also use personal information to administer referral programs, rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by Circle Strategies or its third-party partners, and to invite you to events and relevant opportunities.

Preventing and investigating security and fraud issues: We may use your personal information to prevent, detect, mitigate, and investigate potential security issues, as well as fraudulent or illegal activity on our Services.

Complying with legal obligations: In certain cases, we may have a legal obligation to collect, use, or retain your personal information.

Purposes for which we seek your consent: We may also ask for your consent to use your personal information for a specific purpose that we communicate to you.

 

4. How We Share Your Personal Information

Circle Strategies does not sell your personal information to others. Maintaining your trust in your personal information is a vital part of our relationship with you, and we share your personal information only as described below.

Transactions involving third parties: We make available to your services, software, and content provided by third parties for use on or through our Services. For example, your organization’s administrator may request integration with third-party applications via Circle Strategies’ service options.

Service providers: We engage third-party companies and individuals to perform certain functions on our behalf, for example, provide cloud computing, ai integration, storage services or analyze data. These third-party service providers have access to personal information needed to perform their functions, but may not use it for other purposes.

Protection of us and others: We may disclose your personal information if we believe disclosure is appropriate to comply with the law, enforce or apply our terms or agreements, and protect the rights, property, or safety of Circle Strategies, our employees, customers, users, and others. We may also disclose your personal information in connection with investigating and preventing fraud or security issues relating to our Services.

Business transfers: If Circle Strategies goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its businesses, services, or assets, your personal information may be among the assets transferred. By applicable laws, we will use reasonable efforts to notify you of any transfer of personal information to an unaffiliated third party.

With your consent: We may share personal information with third parties when we have your consent to do so.

 

5. How Long We Keep Your Personal Information

We keep your personal information for as long as it is required to fulfill the relevant purposes described in this Privacy Notice, or for other purposes Circle Strategies deems essential such as complying with our legal obligations, resolving disputes, and enforcing our agreements.

Because these needs can vary for different data types in the context of different Services, actual retention periods can vary significantly. We determine the appropriate retention period for personal information based on the amount, nature, and sensitivity of your personal information processed, the potential risk of harm from unauthorized use or disclosure of your personal information, and whether we can achieve the purposes of the processing through other means, as well as applicable legal requirements (such as applicable statutes of limitation).

After expiry of the applicable retention periods, your personal information will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of that data.

 

6.  International Transfers

Personal information we collect may be stored and processed in your region, in the United States or in any other country where we or our affiliates or service providers maintain facilities. We maintain primary data centers in the United States. We take steps designed to ensure that the personal information we collect under this Privacy Notice is processed as described in this Privacy Notice and according to any applicable laws.

 

7. Cookies

We use cookies and similar technologies to enable our systems to recognize your browser or device, to provide our Services, and to improve your experience.

 

8.  Security

We design our systems with your security and privacy in mind. We maintain a wide variety of compliance programs that validate our security controls. We protect the security of your information during transmission to or from Circle Strategies by using encryption protocols and software.

We maintain technical, physical, and organizational safeguards in connection with the collection, storage, and disclosure of personal information. Our security procedures mean that we may request proof of identity before we disclose personal information to you.

However, no security measure or modality of data transmission over the Internet is 100% secure. Although we strive to use commercially acceptable means to protect your personal information, we cannot guarantee absolute security. You are solely responsible for protecting your password, limiting access to your devices, and signing out of websites after your sessions. For your safety we recommend your passwords are secured using your own encryption systems.

9. Changes to this Privacy Notice

A business associate is a person or entity, other than a member of the Client, who performs functions or activities on behalf of, or provides certain services tom the Client that involve access by the business associate to protected health.

10. Changes to this Privacy Notice

The Services and our business may change from time to time. As a result, it may be necessary for Circle Strategies to make changes to this Privacy Notice. Circle Strategies reserves the right to update or modify this Privacy Notice at any time. Please review this page periodically, and especially before you provide any personal information to us. This Privacy Notice was last updated to be effective as of the “Last Updated” date indicated at the top. Unless stated otherwise, our current Privacy Notice applies to all personal information we have about you and your organization.

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