Privacy Policy
Circle Capital - Online Privacy Policy
I. Introduction
This Privacy Policy explains how Circle Capital collects, uses, shares and safeguards Personal Data and Non-Personal Data on www.Circle Capitalfinancial.com, and any other digital services and platforms officially operated or used by Circle Capital from time to time (“Sites”), as well as by phone or by paper. In certain Sites operated overseas, the privacy policy displayed on those Sites, and not this Privacy Policy, may govern the collection, use and sharing of information.
Circle Capital respects its customers' right to privacy online. We hold our customer information in confidence. We will sometimes ask customers for personal information such as your name, address, e-mail address, occupation and other details. Providing us your information will simply help us offer products and services that we think you'd like to hear about. When you choose to give personal information to us over the Internet that we or our business partners may request, we will endeavor to inform you how we will use the information. When we ask for personal information for any reasons, we will provide a link to this policy statement to make our intentions clear.
Circle Capital will take all appropriate steps to keep the nonpublic personal information confidential that you communicated to us. Those steps include limiting access to customer information databases, communicating this policy statement to all Circle Capital employees who are given access to the database only on a need-to-know basis.
Circle Capital will not sell, rent, or give away our customers' personal information to other companies for use in selling others' products or services. When we do contract with another company to market or advertise products or services for us, we will insist on binding agreements from those companies protecting our customer information. We will vigorously enforce all privacy agreements we have with other companies.
II. Changes to the Privacy Policy
As Circle Capital, its membership, products and services change from time to time, this Privacy Policy is expected to change as well. We reserve the right to amend the Privacy Policy at any time, for any reason. The date of the last revision to the Privacy Policy will be indicated by the "Effective Date" at the bottom of this page.
III. Types of Data We Collect
Personal Data
Circle Capital gathers personal information from our customers so we can better develop our relationship with those customers. Occasionally, we seek customer comments on our products and services. These comments allow us to determine which products and services our customers should be made aware of based on their specific needs.
We collect information (whether online, by phone, or by paper) that enables Circle Capital to identify or contact you (“Personal Data”) to carry out its business purposes. Circle Capital Sites collect this information for a variety of business reasons, including but not limited to, registering for an Circle Capital event or program, purchasing Circle Capital products or services, or otherwise interacting with the Circle Capital.
Circle Capital will not communicate with customers via e-mail or other online delivery devices if the customer disagrees to receive those communications. Customers who believe they are receiving our communications in error or no longer desire to receive them, should inform us and we will remove those customers' names from our mailing lists. We will be judicious in the use of e-mail and paper mail to communicate with customers. We will, at all times, put ourselves in the place of the recipients of our mail and treat our customers as we ourselves would like to be treated.
The types of Personal Data we collect include, but are not limited to:
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General data (e.g., names, dates of birth, home and business addresses, email addresses, Internet protocol addresses and mobile/landline business/personal telephone numbers that are provided by our members/customers)
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Professional data (e.g., prior results of examination(s))
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Government-issued identification numbers (e.g., social security numbers, national identification numbers and tax identification numbers), for example from employees and independent contractors, but not from members unless Circle Capital makes payments to members, such as honoraria or royalties for publishing rights
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Other identification information (e.g., photographs)
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Financial information (e.g., credit and debit card numbers, credit reports, passwords and PIN numbers) for product sales or employment purposes
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Sensitive Personal Data (e.g., racial or ethnic origin, sexual orientation and disability data) for diversity or accessibility purposes
Non-Personal Data
We collect information (whether online, by phone, or by paper) that does not directly identify you as you interact with our Sites (“Non-Personal Data”). The types of Non-Personal Data we collect includes, but is not limited to:
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Site usage (e.g., browsing history, search terms, number of clicks, referring/exit pages, date/time stamp, time on Site)
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Products and services viewed, including advertisements for such products and services
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Computer type, operating system and platform type
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Internet service provider
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Your industry and business (e.g., company size and location, job functions and seniority levels).
IV. How We Use Your Data
In addition to the uses described above, we use your Personal Data, sometimes combined with Non-Personal Data, in a variety of ways including, but not limited to the below, in order to:
Personal Data
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Provide products, information and services you request or that we think you may be interested in
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Respond to your emails or online requests for products, services, or information
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Personalize and improve the usability of the Sites
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Fulfill and/or deliver Circle Capital products and services
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Tailor content, advertising and marketing to you
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Publish membership directories, membership lists and registration lists on the Sites and in print and digital media to allow lawyers and the public to find you; such directories and lists will not include credit card information or personal identification numbers such as social security numbers, as set forth in the “Contact Information” section below
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Identify you when you visit our Sites
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Identify you when you visit our Sites
Non -Personal Data
We use Non-Personal Data to improve the usability of our Sites and for other business reasons. We or other third-party companies also use the Non-Personal Data to provide advertisements and targeted advertisements to you (ads based on the Non-Personal Data). We do not provide Personal Data to third parties with whom we share your Non-Personal Data. Please note that, when you select a link that takes you to sites not operated by the Circle Capital, you may be subject to the privacy policies of these third-party sites.
V. How We Share Your Data
We share your Personal Data, sometimes combined with Non-Personal Data, in a variety of ways including, but not limited to the below:
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Share data with third parties to fulfill service requests and to perform business functions (e.g., Circle Capital contracts with third parties to provide services on our behalf such as data hosting services; packaging, mailing and delivering services; customer support and consulting services; and event registration services).
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Share data with third parties as required by law or to protect Circle Capital in the good-faith belief that such action is necessary to: (a) conform to legal requirements or comply with legal process served on the Circle Capital; (b) protect and defend the Circle Capital’s rights or property; or (c) protect the personal safety of Circle Capital personnel or members of the public in appropriate circumstances.
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Share data with third parties if Circle Capital and/or its assets (or a portion of its assets) are sold, assigned, transferred, or merged, or if Circle Capital undergoes some other change including a change to its corporate form as part of a bankruptcy proceeding or otherwise; information may be transferred as part of that transaction or change.
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Share your email address, but only as permitted by Circle Capital Email Policy, as follows:
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o Your email address will be used only by the Circle Capital and Circle Capital vendors performing services, or offering products on Circle Capital’s behalf. Circle Capital does not sell or rent email addresses to anyone outside the Circle Capital, nor does Circle Capital share email addresses to unrelated third-parties, or affiliates.
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o Circle Capital also shares your email address with third parties to enable Circle Capital to take security measures to help protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of data.
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o Finally, Circle Capital shares email addresses with third parties as necessary for Circle Capital to perform certain services on our behalf, such as packaging, mailing and delivering products and processing event registrations and to respond to your service requests.
VI. How You Can Manage the Processing of Your Data
You can manage your profile and email preferences, including “opting out” of email by contacting us using the information in the “Contact Information” section below. For California residents, please consult the “California Privacy Rights” section for additional considerations.
Our processing of your data is based upon your consent, contract performance (e.g., your purchase of products or membership sign-up/renewal), legitimate business interest (e.g., direct marketing of goods and services), or compliance with law. You have the right to object to our processing of your data or to restrict our processing of your data. In addition, if you have consented to the processing of your Personal Data, you have the right to withdraw your consent at any time.
VII. California Privacy Rights
In addition to the rights as explained in this Privacy Policy California residents who provide personal information to obtain products or services for personal, family, or household use are entitled to request and obtain from us, once a calendar year, information about the personal information we shared, if any, with other businesses for marketing uses. If applicable, this information would include the categories of personal information and the names and addresses of those businesses with which we shared such personal information for the immediately prior calendar year (e.g., requests made in the current year will receive information about the prior year). To obtain this information please email to us at: info@circlecap.com.
VIII. Children
We believe, as a core principle, that it is of utmost importance to protect the privacy of children online. Our services are not intended to be used by, nor do we intentionally collect personal information from, children under the age of 18. We comply with all federal laws and regulations regarding the privacy of children, including the Children's' Online Privacy Protection Act. We do not knowingly collect Personal Data from or market to children under the age of 13.
IX. How We Protect Personal Data
Circle Capital implements commercially reasonable security measures to help protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of data. Except for membership directories, membership lists and registration lists, and the sharing of information as set forth in this Privacy Policy, we restrict access to Personal Data to certain companies who need the data to operate, develop, or improve our services. These individuals or partner organizations are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations. Unfortunately, no data transmission over the Internet or electronic storage is fully secure. Accordingly, and despite our reasonable efforts to protect your Personal Data from unauthorized access, use, or disclosure, Circle Capital cannot guarantee or warrant the security of the Personal Data you transmit to us, or to or from our online Sites. If you have questions about this Privacy Policy, please contact us.
X. Linking to Other Internet Sites
You should be aware that other Internet sites that are linked from the Sites or from an Circle Capital email message may contain privacy provisions that differ from the provisions of this Privacy Policy. To ensure your privacy is protected, we recommend that you review the privacy statements of these other linked sites, applications, or other digital platforms.
XI. How You Can Access, Change and Delete Your Personal Data
We rely on you to update and correct your Personal Data. If you are a user of our Sites, subscriber to Circle Capital publications, purchaser of Circle Capital products and services, or an Circle Capital member, you can review, update and correct your information directly on the Circle Capital’s website or by contacting us using the information in the “Contact Information” section below.
Typically, we retain your Personal Data for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. This may include retaining your Personal Data indefinitely, even after you are no longer an Circle Capital member, in order to provide you with future marketing opportunities and other purposes, as well as to comply with our legal obligations, resolve disputes, or enforce any of our agreements.
Please note that you can request, at any time, that we delete your Personal Data. All requests must be directed to the contact in the “Contact Information” section below. We can decide to delete your Personal Data if we believe that the data is incomplete, inaccurate, or that our continued use and storage are contrary to our obligations to other members, individuals, or third parties. When we delete your Personal Data, it will be removed from our active databases or anonymized so that the data is no longer identified with you, but the data may remain in our archives if Circle Capital determines that it is not practical or possible to delete it.
XII. Cookies and Other Web Devices
Our website sends cookies (e.g., pieces of code or text placed on your computer by us or third-parties when you browse our Sites) to your web browser (if your browser’s preferences allow it) to collect data when you browse our Sites. Cookie settings can be controlled in your Internet browser to automatically reject some forms of cookies. If you view our website without changing your cookie settings, you are indicating your consent to receive all cookies from our Sites. If you do not allow cookies, some features and functionality of our Sites may not operate as expected. In addition to cookies, we place technological tools (and allow certain third parties to place technological tools) such as tags and beacons (e.g., code scripts that are primarily used to track visitors’ activities on our Sites by web analytics software), Internet Protocol (IP) addresses, and other tools, to collect your data for the purposes listed in this Privacy Policy.
XIII. "Do Not Track" Signals
Circle Capital Financial Services, Inc.’s website does not respond to Web browser “Do Not Track” signals at this time. To prevent Circle Capital Financial Services, Inc. or third parties from tracking, you can access your browser settings and disable or delete your cookies.
XIV. Transmission of Data to Other Countries
Your Personal Data is processed in the United States, where privacy laws may be less stringent than the laws in your country and where the government, courts, or law enforcement may be able to access your data. By submitting your Personal Data to us, you agree to the transfer, storage and processing of your Personal Data in the United States.
XV. Breach Notification
In the event we determine the occurrence of a data security incident, we will notify you by email, US mail, telephone, or other means as permitted by law.
XVI. Contact Information
If you have questions, comments, or complaints concerning our privacy practices or if you wish to change, access, or remove your Personal Data, please contact us as indicated below. We will attempt, where practical, to respond to your requests and to provide you with additional privacy related information.
Circle Capital
(562) 395-8726 or info@circlecap.com
XVII. E-mail and Request Form communications
E-mail and forms are fast and convenient communication means. However, they are not entirely secure. We recommend you care not sending E-mails and request form containing any personal nonpublic or sensitive information that you would not want viewed by a third party.
XVIII. Updates to the Online Privacy Statement
This Online Privacy Statement is subject to change. Please review it periodically. If we make changes to the Online Privacy Statement, we will revise the “Last Updated” date in the “Effective Date” section of this Statement. Any changes to this Statement will become effective when we post the revised Statement on the Site. Your use of the Site following these changes means that you accept the revised Statement.
XIX. Phone Number Disclaimer
By providing my phone number to Circle Capital, I agree and acknowledge that Circle Capital may send text messages to my wireless phone number for any purpose. Message and data rates may apply. Message frequency will vary, and you will be able to Opt-out by replying “STOP”.
XX. Phone Number Privacy Policy
No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
Effective Date: January 1, 2024