PRIVACY POLICY

Circle In Privacy Policy

Last modified: February 4, 2020

Circle In Pty Ltd (ABN 74 609 227 018) (Circle In, us, we, our) maintain a policy of confidence concerning the personal information we collect from and about individuals (you, your) (Privacy Policy).

Circle In offers our customer clients an employee engagement platform available through a personalised website and accessible on any device. Using our platform, we build a personalised portal that helps employees and managers stay connected whilst balancing other caring responsibilities.

This Privacy Policy applies to the information and data collected by Circle In as a controller, including the information collected on our Website and Platform, or through other channels as described below. It also describes your choices regarding use, access and correction of your personal information.

By visiting our website, using our services or otherwise interacting with us, you consent to our processing of your personal information in accordance with this Privacy Policy and any other arrangements that apply between us.

If you do not agree with the data practices described in this Privacy Policy, you should not use the Website or Platform.

We periodically update this Privacy Policy. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by sending you an email notification.

While we will notify you of any material changes to this Privacy Policy prior to the changes becoming effective, we encourage you to review this Privacy Policy periodically. Any revised Privacy Policy will take effect when it is published on our website and your continued use of our website or services will constitute your consent to these changes.

If you have any questions about this Privacy Policy or our treatment of the information you provide us, please write to us by email at privacy@circlein.com or by mail to Circle In, Suite G06, 175 Sturt St, Southbank, Melbourne, VIC 3006. Attn: Privacy 

1. Information We Collect

“Personal information” or “personal data” is any information about you, from which you can be identified. Our Processing of your personal information will depend on our relationship with you, the circumstances of collection and the types of products and services you request from us. We may collect additional personal information from you from time to time.

When You Visit our Websites
You are free to explore the Website without providing any Personal Information about yourself. When you visit the Website, use our Platform, or request assets, we request that you provide Personal Information about yourself.

Through Your Use of our Services
When you register with us, access and use our services, contact our support team, make an enquiry, respond to our surveys or provide feedback or comments or otherwise interact with us or provide your personal information to us. Personal information may include your name, email address, telephone number and employment-related information. 

If you are an employee of our employer client, personal information may include your name, email address, your parenthood stage,  gender, number of kids, age bracket, length of time with your employer, whether you manage people, your manager’s name and email; and any other personal information that you submit to us, via our site or otherwise.

Indirectly from Your Employer
When your employer uses our services, your employer may provide your information to us on your behalf, for example when they register you as a user of our services or contact our support team for issues relating to your account. We may collect your name, email address, journey stage, managers name and employment-related information. Where we receive personal information about you from your employer, we require that your employer has provided you with the information set out in this Privacy Policy, has collected and disclosed that information with your knowledge or consent and ensure you have not objected to our processing of your personal information.

Employment
If you are an Circle In employee or a prospective employee of Circle In, we may collect personal information directly from you or indirectly from recruitment agencies, your referees or past employers as part of the recruitment process and human resources management. This may include name, address, phone number, employment history and experience and other employment-related information. If you are an employee, we may also collect sensitive information about you and you consent to us collecting this information. 

“Personal Information”
This refers to any information that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, email address, company name, address, phone number, and other information about yourself or your business.

Personal Information includes Navigational Information where such information can directly or indirectly identify an individual. Navigational information refers to information about your computer and your visits to the Websites such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed. Please see the “Use of Navigation Information” section below. Except for this, we do not collect Sensitive Information from you.

If someone other than you provides us with personal information about you that we did not ask for, or you provide us with unsolicited personal information, we will only hold, use or disclose this information if we determine that we could have collected this information from you had we asked for it. In this circumstance, we will take all reasonable steps to notify you of the collection of that information. If we could not have collected this personal information, we will lawfully de-identify or destroy that personal information.

“Sensitive Information”
We do not collect sensitive information about you, unless you provide it to us voluntarily. For example sensitive information refers to  credit or debit card numbers, personal financial account information, Social Security numbers, passport numbers, driver’s license numbers or similar personal identifiers, racial or ethnic origin, physical or mental health condition or information, or other employment, financial or health information.

You consent to us collecting sensitive information which you provide to us voluntarily. If we need to collect any sensitive information for a specific purpose, we will ask for your consent.

Log Files
When you view content provided by us, we automatically collect information about your computer hardware and software. This information can include your IP address, browser type, domain names, internet service provider (ISP), the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, clickstream data, access times and referring website addresses. This information is used by Circle In to provide general statistics regarding use of the Websites. For these purposes, we do link this automatically-collected data to Personal Information such as name and email address.

Information About Children
The Websites are not intended for or targeted at children under 16, and we do not knowingly or intentionally collect information about children under 16. If you believe that we have collected information about a child under 16, please contact us at privacy@circlein.com, so that we may delete the information.

2. How We Use Information We Collect

Compliance with Our Privacy Policy
We use the information we collect only in compliance with this Privacy Policy.

We Never Sell Personal Information
We will never sell your Personal Information to any third party.

Use of personal information
In addition to the uses identified elsewhere in this Privacy Policy, we may use your Personal Information to:

  • improve your browsing experience by personalizing the Websites and to improve our Platform and Website;
  • send information or Circle In content to you which we think may be of interest to you by email, or other means and send you marketing communications relating to our business;
  • promote use of our services to you and share promotional and information content with you in accordance with your communication preferences;
  • send information to you regarding changes to our Customer Terms of Service, Privacy Policy (including the Cookie Policy), or other legal agreements

Legal basis for processing Personal Information (EEA visitors only)
If you are a visitor located in the European Economic Area (“EEA”), our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we have your consent to do so, where we need the personal information to perform a contract with you, or where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms. In some cases, we may also have a legal obligation to collect personal information from you.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

Use of Navigational Information
We use Navigational Information to operate and improve the Websites. We may also use Navigational Information alone or in combination with Personal Information to provide you with personalized information about Circle In.

Customer Testimonials and Comments
We post customer testimonials and comments on our Websites, which may contain Personal Information. We obtain each customer’s consent via email prior to posting the customer’s name and testimonial.

Security of your Personal Information
We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure. All Personal Information is protected using appropriate physical, technical and organizational measures. 

Social Media Features
Our Websites include Social Media Features and widgets, such as the Share This button or interactive mini-programs that run on our sites. These features may collect your IP address, which page you are visiting on our sites, and may set a cookie to enable the feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Websites. This Privacy Policy does not apply to these features.  Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.

External Websites
Our Websites provide links to other websites. We do not control, and are not responsible for, the content or practices of these other websites. Our provision of such links does not constitute our endorsement of these other websites, their content, their owners, or their practices. This Privacy Policy does not apply to these other websites, which are subject to any privacy and other policies they may have.

Public Forums
We offer publicly accessible blogs. Please keep in mind that if you directly disclose any information through our public blogs, this information may be collected and used by others. We will correct or delete any information you have posted on the Websites if you so request, as described in “Opting Out and Unsubscribing” below.

Retention of Personal Information
How long we keep information we collect about you depends on the type of information. as described in further detail below.  After such time, we will either delete or anonymise your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.

We retain Personal Information that you provide to us where we have an ongoing legitimate business need to do so (for example, as needed to comply with our legal obligations, resolve disputes and enforce our agreements).

When we have no ongoing legitimate business need to process your Personal Information, we securely delete the information or anonymise it or, if this is not possible, securely store your Personal Information and isolate it from any further processing until deletion is possible. We will delete this information at an earlier date if you so request, as described in the “How to Access & Control Your Personal Data” below.

If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us or ceased using your Circle In account.  We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

3. How we Share Information we Collect

We may disclose personal information in accordance with the applicable law and for the purposes described above, including:

  • To your employer who is our client;
  • To our related bodies corporate;
  • To anyone to whom our assets or businesses (or any part of them) are transferred;
  • When we may be required, authorised or permitted by law, including to government agencies, regulatory bodies and law enforcement agencies; and
  • To any other third party where you have provided your consent.

We may also disclose personal information to third parties such as our contractors, suppliers, agents and service providers who help us deliver, administer and support our functions and activities, including:

  • Hosting our servers and website;
  • Delivering marketing and digital marketing services;
  • Conducting research, surveys and data analysis;
  • Providing IT services;
  • Data processing, storage and back-up; and
  • Processing payments.

Service Providers
We employ other companies and people to provide services to visitors to our Websites and our customers and users of the Platform and may need to share your information with them to provide information, products or services to you. Examples may include removing repetitive information from prospect lists, analyzing data or performing statistical analysis, providing marketing assistance, supplementing the information you provide us in order to provide you with better service, and providing customer service or support. In all cases where we share your information with such agents, we explicitly require the agent to acknowledge and adhere to our privacy and customer data handling policies.

International Disclosures
Some of the third parties we disclose your personal information to may be based or have servers located overseas in various countries, including USA. Before we disclose your information to our overseas recipients, we will take all reasonable steps to ensure that your information is only Processed for authorised purposes and adequately protected using the appropriate technical, organisational, contractual or other lawful means. You consent to us disclosing your personal information to overseas recipients on this basis.

Non-Australian Resident Data
Circle In is based in Australia, the USA and the UK and your information is stored in servers located in Australia, the USA and UK respectively. Please be aware that as Australia is where our central operations are located, any information you provide us, may be transferred from your country of origin to Australia. Your decision to provide such information to us or allow us to collect such information constitutes your consent to this information transfer.

Corporate Events
If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information gathered by Circle In on the Websites and the Platform. In this event, you will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your Personal Information, and choices you may have regarding your Personal Information.

Compelled Disclosure
We reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order, or legal process.

4. Direct Marketing

If you are our client, we may, from time to time, send direct marketing communications to you about our activities and services and other material that we consider you would find interesting or useful. If you do not wish to receive such direct marketing communications, you can always opt out. If you are receiving email communications from us, there will be a mechanism to opt out contained in each of those emails. To stop receiving other communications from us, you can contact us via any of the channels listed below.

If you choose to opt out of all direct marketing communications, please note that Circle In may still contact you and your employees for other reasonable purposes, including information that Circle In is legally required to send, notifications of changes to Circle In services or policies and information regarding the use, rights, benefits or obligations of users of our services.

5. Cookies and Similar Technologies

Cookies
Circle In and its partners use cookies or similar technologies (such as web beacons) to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole.  A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the Site. Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not.

To find out more about how we use cookies on our Websites and how to manage your cookie preferences please see our Cookie Policy.

Advertising
We partner with third party ad networks to either display advertising on our Web site or to manage our advertising on other sites. Our ad network partners use cookies and Web beacons to collect information about your activities on this and other websites to provide you targeted advertising based upon your interests.  If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here: http://preferences.truste.com/ (or if located in the European Union, by clicking here: http://www.youronlinechoices.eu/). Please note this does not opt you out of being served advertising.  You will continue to receive generic ads.

Third Party Tracking Technologies
The use of cookies and web beacons by any tracking utility company is not covered by our Privacy Policy or Cookie Policy.

6. How to Access & Control Your Personal Data

Reviewing, Correcting and Removing Your Personal Information
We will take all reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date, and we will try to confirm your details through our communications with you and promptly add updated or new personal information to existing records when we are advised. However, we rely on the accuracy of personal information as provided to us both directly and indirectly. We encourage all users (whether of the Website, on our Social Channels or Platform) to regularly review and update their personal information. If any of your details change, please notify us as soon as you can or log into your online profile or subscription centre to update it. If you believe we are holding information about you that is inaccurate, incomplete, irrelevant or misleading, you can ask us to correct it, or delete it altogether.

You have the following data protection rights:

  • You can request access, correction, updates or deletion of your personal information.
  • You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information.
  • If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to a data protection authority about our collection and use of your personal information. Contact details for data protection authorities in the EEA, Switzerland and certain non-European countries (including the US and Canada) are available here.)

To exercise any of these rights, please contact us at privacy@circlein.com or by mail to Circle In, Suite G06, 175 Sturt St, Southbank, Melbourne, VIC 3006. Attn: Privacy. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.

To Unsubscribe From Our Communications
You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our emails, updating your communication preferences, or by sending us email us at privacy@circlein.com or by mail to Circle In, Suite G06, 175 Sturt St, Southbank, Melbourne, VIC 3006. Attn: Privacy. Customers cannot opt-out of receiving transactional emails related to their account with us.

7. Your California Privacy Rights
Circle In is both a “business” and a “service provider” under the CCPA. This Section 7 applies to information we collect in our role as a business, or when we interact directly with you. 

If you have any questions or would like to request access or deletion of your personal information please reach out to us at privacy@circlein.com.  

Your Rights

If you are a California resident, there are some additional rights that may be available to you under the California Consumer Protection Act (“CCPA”). 

When we act as a business, you can exercise your rights under the CCPA by following Section 6 of this Privacy Policy (“How to Access & Control Your Personal Data”)

8. Making A Complaint

We take your complaints seriously and we will attempt to resolve any issues quickly and fairly. If you think that an act or practice of Circle In has interfered with your privacy in relation to your personal information, you can contact us using the details below. Please include your name, email address, telephone number and clearly describe your complaint.

If we cannot resolve your complaint to a satisfactory standard, you are entitled to lodge your complaint:

With the Office of the Australian Information Commissioner at: http://www.oaic.gov.au; or

For residents of the European Economic Area and the UK, with the relevant supervisory authority. A list of EU national data protection authorities can be found on the European Commission website at: https://ec.europa.eu/info/strategy/justice-and-fundamental-rights/data-protection_en.

Contact
Email: privacy@circlein.com

Post:
Privacy Officer
Circle In, Suite G06
175 Sturt St
Southbank, Melbourne
VIC 3006.