Privacy Policy

Welcome to CircYOUity, a service provided by CircYOUity Limited and its subsidiaries, including CircYOUity, Inc. (“CircYOUity”, “we”, “our”, “us”).

Your privacy is important to us. This Privacy Policy explains how we collect, store, use, disclose and otherwise process your information when you use CircYOUity.com and m.CircYOUity.com (together, the “Website”), our mobile and desktop apps (the “Apps”) and all related sites, players, widgets, tools, apps, data, software, APIs and other services provided by CircYOUity (the “Services”).

This Privacy Policy explains the following, amongst other things:

Information relating to our use of cookies and similar technologies is set out in our Cookie Policy, which forms part of the Privacy Policy. When we refer to the Privacy Policy, we are referring to the Privacy Policy and Cookie Policy.

Please take some time to read this Privacy Policy, including the Cookie Policy, along with our Terms of Use, in order to ensure you understand and are comfortable with our use and disclosure of your personal information. If you see an undefined term in this Privacy Policy, it has the same meaning given to it in our Terms of Use.

Please note that this Privacy Policy only applies to the Website, the Apps and the Services (together, the “Platform”). When using the Platform, you may find links to other websites, apps and services, or tools that enable you to share information with other websites, apps and services. CircYOUity is not responsible for the privacy practices of these other websites, apps and services and we recommend that you review the privacy policies of each of these websites, apps or services before connecting your CircYOUity® account or sharing any personal data.

If you do not agree to any of the provisions of this Privacy Policy, you should not use the Platform. If you have any questions or concerns about this Privacy Policy, you can contact us through the Help or at [email protected].

Data Controllers

When this policy mentions “CircYOUity,” “we,” “us,” or “our,” it refers to the CircYOUity entity that is responsible for your information under this Privacy Policy (the “Data Controller”).

  • If you are located in the United States, CircYOUity Inc. is the Data Controller of your personal data provided to, or collected by or for, or processed in connection with, our Platform;

  • If you are located outside the United States, CircYOUity Ltd. is the Data Controller of your personal data provided to, or collected by or for, or processed in connection with, our Platform;

  • We may share your data within our corporate group of companies that are related by common ownership or control (“CircYOUity Group”) and data of US users may be processed by CircYOUity Ltd. on CircYOUity Inc.’s behalf.

Our Privacy Principles

CircYOUity is committed to putting users first and believes you should know what data we collect about you, why we collect it, and how we use and share it. That’s why we’ve designed this Privacy Policy to give you simple, clear, and actionable information about our privacy and data protection practices.

We believe users should also have meaningful choices over the data we collect, use and share as described in this Privacy Policy, your Settings and the Help. We encourage you to take full advantage of these tools so you can make the best decisions about the data you share.

Information We Collect

All the personal information we collect is related to providing the Platform and its features and falls into three general categories:

  • Information you provide to us
  • Information collected automatically
  • Information we obtain from third parties

Information You Provide

We ask for and collect the below personal information when you use the Platform. This information is necessary for the adequate performance of the contract between you and us and to allow us to comply with our legal obligations.

We process this information in light of our legitimate interest in improving the Platform and giving our users the best experience, and where it is necessary for the adequate performance of the contract between us and you. Without it, we may not be able to provide you with all the requested services and features of the Platform.

You don’t need to register for a CircYOUity account in order to visit or use our Platform. However, certain Services require that you register for an account and, by doing so, you will need to provide us with certain information:

  • Account Information - When you register any kind of CircYOUity account, you will need to provide your email address (except when you sign-up with Facebook or Google and don’t give your permission to share it with CircYOUity), your age, and choose a password. In addition, if you purchase a Subscription, you will also need to provide your real name, billing address, and payment verification information.

  • Profile Information - you may choose, at your discretion, to provide additional information for your public profile on CircYOUity® – for example:

    • your real name

    • a user name (which may be your real name or a pseudonym)

    • the city and country in which you live

    • a profile picture, profile header image or avatar

    • information about how you categorize yourself with respect to your content (for example, whether you are a musician, a label or some other category of creator)

    • details of your other websites and social media profiles, including links to those pages

    • your gender if you wish to provide it

    • any additional information you provide as part of your public profile, such as your real name, and links to your website and other social media profiles (but not your email address), will be published on your profile page. This information will be publicly accessible and may be viewed by anyone accessing the Website, or using our API or other Services. Please bear this in mind when considering whether to provide any additional information about yourself

  • Communications - When you communicate with CircYOUity by email or through the Platform, or use the Platform to communicate with other users, we collect information about your communication and any information you choose to provide.

  • Survey Information - If you participate in any survey, you may provide certain personal data as part of your response, unless you respond anonymously.

  • Information You Post - You may provide personal data when you upload Creations to the Platform, or when you post comments, or contribute to community discussions.

Information We Collect Automatically

There is certain information that we collect automatically as the result of your use of the Platform, or through the use of cookies and other web analytics services as described in our Cookie Policy. This information generally includes:

  • Usage Information - We collect information about your interactions with the Platform, including the pages that you visit and links you click on, streaming, offline listening or downloading tracks, uploading or recording tracks, connecting your Facebook or Google+ account, sharing a Creation with another user, following or unfollowing another user, joining or leaving a group, posting a comment, performing a search, the time, frequency and duration of your visits to the Platform, and whether you interact with email messages, for example, if you opened, clicked on, or forwarded the email message.

  • Log Data – We automatically collect log information when you use the Platform, even if you have not registered for an account or logged in. That information includes, among other things: details about how you’ve used the Platform (including links to third party sites or services), Internet Protocol (IP) address, access times, your browser type and operating system, device information, device event information (e.g., crashes, browser type), and the page you’ve viewed or engaged with before or after using the Platform.

  • Cookies – We use cookies and other similar technologies, such as pixels, local storage, and mobile device identifiers and may also allow our business partners to use these tracking technologies on the Platform, or engage others to track your behavior on our behalf. For more information on our use of these technologies, see our Cookie Policy.

  • Location Data – When you use certain features of the Platform, we may collect data about your general location (e.g. IP address). We use this data to provide you with location-based services (such as advertising and personalized content). Most mobile devices allow you to control or disable the use of location services for applications in the device’s settings.

  • Device Information – We collect information from and about the devices you use, including how you interact with the Platform and information about device itself, such as the hardware model, operating system, IP addresses, cookie information, device settings, mobile device and advertising identifiers, apps installed, browser type, language, battery level and time zone. Apple’s iOS Advertising Identifier (IDFA) and Google’s Android Advertising ID are examples of device identifiers. This information allows us to recognize and associate your activity, and provide personalized content and advertising, consistently across all of your devices.

  • Software Development Kits – We may use third parties including our business partners and service providers who use mobile SDKs to collect information and information related to how mobile devices interact with the Platform. An SDK is computer code that app developers can include in their apps to enable ads to be shown, data to be collected and related services and functionality to be implemented. A mobile SDK is in effect the mobile app version of a pixel tag or beacon. We may use this technology, for instance, to analyze how you interact with content and advertisements and to enable analytics or other features through mobile devices.

  • CircYOUity Widget – Other websites may integrate CircYOUity widgets; when you visit a website with a CircYOUity widget embedded, we may receive certain information, including information about the website you visited. CircYOUity and the widget may be able to recognize you, and in some cases the widget may be used to show personalized content. We know when you interact with a widget, and websites containing the widgets may receive this information as well.

Information From Third Parties

  • Single-Sign Ons – If you sign up for CircYOUity through a third party application like Facebook or Google, you authorize us to collect your authentication information, such as your username and encrypted access credentials, and other information available through the third party application account, including the following information:

    • Facebook Connect – CircYOUity allows you to sign up and sign in using your Facebook account. If you sign up using Facebook, Facebook will ask your permission to share certain information from your Facebook account with CircYOUity. This includes your Facebook user ID, first name, last name, email address (optional), gender, locale, your time zone, birthday and profile picture. This information is collected by Facebook and is provided to CircYOUity under the terms of Facebook’s Privacy Policy. You can control the information that we receive from Facebook using the privacy and data settings in your Facebook account. If you signed up using Facebook by mistake, you can delete your account from the Account page within your Settings at any time, or you can contact us via the Help.

    • Google+ – You can sign up and log in to CircYOUity using your Google+ account. When you sign up using Google+, Google will ask your permission to share certain information from your Google+ account with CircYOUity. This includes your Google+ user ID, username, email address, birthdate or -range (optional), gender (optional), and avatar (optional). This information is collected by Google and is provided to us under the terms of Google’s Privacy Policy. You can regulate the information that we receive from Google using your Google activity controls. If you signed up using Google by mistake, you can delete your account from the Account page within your Settings at any time, or you can contact us via the Help.

  • Service Providers and Business Partners – We may also receive information about you from our service providers and business partners, including companies that assist with payment processing, analytics, data processing and management (e.g. to measure ad quality and responses to ads, and to display ads that are more likely to be relevant to you, including for CircYOUity products) account management, hosting, customer and technical support, and other services which we use to personalize your CircYOUity experience. We explain in more detail why and how we use this information below.

How We Use Your Information

We use the personal information we collect from you, including with the help of automated systems and decision making, for a range of different business purposes according to different legal bases of processing and subject to the choices you make in your Settings.

  • Provide, Improve, and Develop the Platform

    • To operate and maintain your CircYOUity account, and to provide you with access to and use of the Platform. Your email address and password are used to identify you when you log into the Platform. Your device-IDs are used to ensure that you are in control of the devices that have access to your Subscription.

    • To identify you as the creator of the Creations that you upload, the comments that you post and/or the other contributions that you make to the Platform.

    • To provide creators with stats and insights about users’ listening behavior of their Creations, (i.e. streaming and downloading their Creations or following their profiles).

    • We conduct surveys and research, test features in development, and analyze the information we have to evaluate and improve products and services, develop new features, and conduct audits and troubleshooting activities.

    • If you purchase a Subscription, your name, address and payment verification information will be used to process your account subscription and renewals and to collect your payment. All payment verification information is transmitted using industry-standard SSL (Secure Socket Layer) encryption. CircYOUity also complies with the Payment Card Industry Security Standards.

    • Your email will be used to send you service updates and notifications about your account.

    • To respond to you about any comment or enquiry you have submitted.

    • We use your age to enable age restrictions.

We process this information in light of our legitimate interest in improving the Platform and giving our users the best experience, and where it is necessary for the adequate performance of the contract with you (e.g. Terms of Use).

  • Maintain a Safe and Secure Environment

    • Detect and prevent fraud, spam, abuse, security incidents, and other suspicious activity.

    • Verify and authenticate your identity and prevent unauthorized or illegal activity.

    • Enhance the safety and security of our products and services.

    • Conduct security investigations and risk assessments.

    • To prevent or take action against activities that are, or may be, in breach of our Terms of Use, Community Guidelines or applicable law.

    • To provide you with customer and technical support.

We process this information in light of our legitimate interest in improving the Platform and giving our users the best experience, and where it is necessary for the adequate performance of the contract with you (e.g. Terms of Use).

  • Personalize Content, Advertising and Marketing

    • To improve your experience on the Platform by providing personalized content, recommendations, and features.

    • To customize the content and measure performance of any email, push notification, or in-app message we may send to you.

    • Administer sweepstakes, contests, or other promotional activities or events sponsored or managed by CircYOUity or its partners.

    • Use automated systems and decision making to profile user characteristics and infer preferences based on information that you provide to us, your interactions with the Platform and content, your profile information, and information obtained from third parties. This data is used to create groups of users, called segments, who share similar characteristics and interests; we use segments to serve personalized content, advertising, and marketing messages. We also use automated systems to associate your activity over time across devices, and may associate activity and accounts under a single user ID, in order to determine that certain devices are related to each other and provide you with a personalized experience across devices and platforms.

    • To deliver targeted marketing for CircYOUity products on and off the Platform and measure the success of those campaigns. When you see our ads on a third party website or apps, we or third party services we engage for this purpose, may collect information that your browser or mobile app makes available when seeing the ad (e.g IP address, referral URL, browser details, timestamp of request), including whether a click converted to an actual purchase of a Subscription. Please see the privacy policy of such third party websites to understand what data may be collected and how to opt-out.

    • Ads are more effective when they are shown to people who are likely to be interested in the product or service advertised. For this reason, we use the information we collect and receive to help us select which ads to show you on behalf of advertisers. This includes information you choose to provide to us (e.g. age and gender) and make available to us when you interact with the Platform (e.g. by listening, liking or creating playlists), as well as general location data. We may also display ads based on the page you’re on or content you have recently viewed, searched, or listened to. This allows us to show you ads that will likely be more relevant and interesting to you.

    • When we engage third party services such as ad-networks and exchanges that enable us showing you targeted ads, we may also allow them to collect certain information such as cookie data and device identifiers. That information is used to synch or match users to segments and serve targeted advertising, including based on device activity, inferred interests, and general location information.

    • Combine information we collect about you with information from business partners and use it to serve more relevant advertising.

We may use your data for other purposes, provided we disclose the purposes and use to you at the relevant time, and provided that you consent to the proposed use of your personal data.

Sharing of Your Information

This section describes how the information collected or generated through your use of the Platform may be shared by you or by us.

  • Through Your Profile – Any information in your public profile (other than your email address) will be accessible by other users of the Platform, who may view your profile information, listen to and comment on any of your public Creations, add themselves to your list of followers, and send you messages. If you listen to any Creations uploaded by a CircYOUity Pro user, the fact that you have listened to those Creations will be shared with that Pro user, and that you are following that Pro user, so that they can track the popularity of their Creations. Similarly, if you comment on any Creations on the Platform, your comments will be available to all users of the Platform.

  • With Your Consent – We will disclose your information if you have agreed that we may do so. We will make this clear to you at the point at which we collect your information, including the purpose(s) for which we will use the data.

  • Service Providers – We use a variety of third party service providers, some of who may be located outside of the European Economic Area (“EEA”), to provide services to us or to our users on our behalf. These service providers have access to your information solely to perform these tasks on our behalf, and are contractually bound to implement appropriate organizational and technical security measures to protect against unauthorized disclosure of personal data, and only to process personal data in accordance with our instructions and to the extent necessary to provide their services to us. We need to share your information, including personal information, in order to ensure the adequate performance of our contract with you.

  • Content Partners – The Platform allows you to listen to a variety of content, including licensed streaming content from our content partners. We share information with these content partners that license this content to help them understand how the content they provide is performing, including insights about general user listening trends and preferences. We use technical measures to ensure the data is de-identified and/or aggregated so it does not identify you directly. We share this data based on our legitimate interest in helping content partners deliver high performing content and to ensure the fulfillment of our contract with those partners.

  • Advertising – We share the data collected about you, generally in hashed, aggregated, or de-identified forms with advertisers and advertising service providers and business partners in order to serve ads based on your interests and measure the reach and effectiveness of those ads, including whether a user took an action (e.g. purchase a product). We may also share cookie data and device identifiers with service providers for data matching purposes, in order to improve ad targeting.

  • Social Media – For users outside of the EU/EEA, where permissible under applicable law, we may share your email address (in hashed form, so that it does not identify you) with Facebook in order to target you with ads for CircYOUity products on Facebook and on third party websites and applications in the Facebook Audience Network. We also allow Facebook and other social media platforms to collect information through cookies and similar technologies like pixels in order to serve ads for CircYOUity on those third party websites and apps and drive users to our Platform. In order to measure the effectiveness of and optimize these marketing campaigns, these technologies track activity taken across devices after a user sees a CircYOUity ad, in order to determine performance metrics like sign ups, visits to the Platform, and purchases. We undertake these activities based on our legitimate interest in acquiring new customers and offering products we think you may be interested in. Any questions regarding how these social media platform service provider processes your personal data should be directed to such third party platform.

  • Aggregated Data – We may also share aggregated information (information about our users that we render in such a way that it no longer identifies or references an individual user) and other pseudononimized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.

  • API Integrations – CircYOUity has an open application-programming interface (API), which enables application developers to integrate elements of the Platform into other apps. Some of these developers may be located outside of the EEA. Please bear this in mind when deciding what information to publish on your profile. For information on how to limit the information that is available through the API, please see the Your Choices and Controls section below.

  • Third Party Applications – If you choose to connect your CircYOUity® account to other apps or social networks such as Facebook and Google+ you may be sharing certain information with these apps or networks. Content that you share with Facebook will appear on your timeline and in your Facebook friends’ newsfeeds. Content you share with Google will be seen by the people from your Google+ circles when they visit your Google+ profile, make relevant Google searches, on Google-served ads, and the services selected in your Google account settings. In the case of connected apps, you will need to provide the app developer with full access to your CircYOUity® account in order to upload and download Creations, or comment on, favorite, or repost Creations from within the app. This means sharing your public information, plus access to your private Creations. CircYOUity is not responsible for these other apps or networks, so please make sure you only connect your account with apps or services that you trust. For information on how to control the information that you share, and how to disconnect your account from these apps, please see the Your Choices and Controls section below. If you do not want this information shared with Facebook or Google, please change your CircYOUity Settings on our Platform or in those networks.

  • Compliance with Laws – We may disclose your information to courts, law enforcement agencies, and governmental authorities (i) to comply with our legal obligations, (ii) to comply with legal process and to respond to claims asserted against CircYOUity, (iii) to respond to verified requests relating to a criminal investigation or alleged or suspected illegal activity or any other activity that may expose us, you, or any other of our users to legal liability, (iv) to enforce and administer our Terms of Use and other agreements with users, or (v) to protect the rights, property or personal safety of CircYOUity, its employees, and members of the public.

  • Protecting our Rights – We may disclose your information if we feel this is necessary in order to protect or defend our legitimate rights and interests, or those of our users, employees, directors, officers, or shareholders, and/or to ensure the safety and security of the Platform and/or the CircYOUity® community.

  • To Our Affiliates – To enable and support us in providing the Platform and Services, we may share your information, including personal information, within the CircYOUity Group. The data sharing is necessary for the performance of the contract between you and us and is based on our legitimate interests in providing the Platform globally.

  • Change of Control – We may also share your personal data as part of a sale, merger or change in control of CircYOUity, or in preparation for any of these events. Any other entity that buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

Cookies and Similar Technology

As further described in our Cookie Policy we use cookies and similar technologies (e.g., pixels, local storage, and device identifiers) to recognize you and/or your device(s) on and off the Platform, and across devices and devices. To the extent allowed by your settings or your device, we also allow third parties to use cookies as described in our Cookie Policy in order to track user behavior on and off the Platform in order to show you ads based on your interests and preferences. You can control cookies through your browser and other tools as described in the Cookie Policy, as well as through your CircYOUity Settings .

Information Security

CircYOUity maintains technical, administrative, and physical safeguards that are designed to prevent unauthorized access, use or disclosure of personal information we collect or store. We regularly monitor our systems for possible vulnerabilities and attacks. However, it is not possible to guarantee the security of information transmitted over the Internet. You use the Platform and provide us with information at your own discretion and risk.

International Data Transfers

CircYOUity operates globally and may share your information internally within the CircYOUity Group, and third parties for the purposes described in this Privacy Policy. Information collected within the EEA may, for example, be transferred to countries outside of the EEA for the purposes as described in this Privacy Policy. We utilize appropriate safeguards such as Standard Contractual Clauses approved by the European Commission, or another legally approved mechanism, to ensure the lawful transfer of your personal data outside of the EEA.

Children

CircYOUity is not intended for use by children. Anyone under the age of 16 in the EEA, or 13 in the United States and the rest of the world, is not permitted to use the Platform and must not attempt to register an account or submit any personal information to us. We do not knowingly collect any personal information from any person who is under the age of 16 or 13, as the case may be, or allow them to register an account. If it comes to our attention that we have collected personal data from a person under the age of 16 or 13, as applicable, we will delete this information as quickly as possible. If you have reason to believe that we may have collected any such personal data, please notify us immediately at [email protected].

Your Choices and Controls

We do our best to give you as much choice as possible regarding the amount of information you provide to us, and the control you have over that information.

  • Managing CircYOUity Settings. If you register an account, you may manage the content and information you share when you use CircYOUity through your account Settings , including for the features explained below. You are solely responsible for keeping your Settings up-to-date.

    • Email – You can adjust your Settings in the Notification tab to disable email and desktop notifications (other than important service updates and essential notifications about the Platform or your account). All commercial emails and newsletters also allow you to unsubscribe at any time.

    • Analytics – To control whether we collect analytics and usage information, including through cookies and similar technologies, you can adjust your Settings in the “Analytics” tab.

    • Marketing – If you do not want to receive personalized ads, offers or other marketing messages for CircYOUity products or services, you can adjust your Settings in the “Communications” tab.

    • Advertising – If you do not want CircYOUity to deliver “interest based” or personalized ads for third party products, you can adjust your settings in the “Advertising” tab. Please note, however, that even if you opt out of personalized ads, you may still see ads, but they will likely not be as relevant or useful to you.

    • Content Sharing – It’s not possible to make your account entirely private. However, you do have the option to make all of your tracks, playlists and other uploads private. This means that no one will be able to access and listen to your Creations without your explicit permission.

    • Third Party Apps – If you have chosen to connect your account to a third-party application, like Facebook or Google, you can disable permission for the app by adjusting your Settings in the “Connections” tab.

    • Third Party Developers – CircYOUity® has an open API, which allows third party developers to build some really cool apps as an extension of the Platform. If you would prefer that your Creations are not made available to third party app developers, you can disable API access within the Creation page for each of the Creations that you upload. Click on the pencil icon in the waveform player, and uncheck the “Apps enabled” box at the bottom of the page. Please note that your public profile information will still be accessible, but this does not include anything that is not publicly available on the Website.

    • Deleting Your Account – If you have an account and would like to delete it, you may do so by adjusting you Settings in the Account tab. If you delete your account, all data associated with your account (except for backup copies), including the Creations that you have uploaded and the usage data associated with those Creations, will be deleted and may not be recoverable. We therefore advise you to copy or backup all content uploaded to your account before deletion. Even if you delete your CircYOUity account, it is possible that your information may still show up in some internet search results for a short while afterwards, if the search engine maintains a temporary cache of web pages. Search engines’ caching processes are outside of CircYOUity’s control and therefore we cannot be responsible for any information that remains cached by search engines after that information has been removed from the Platform. Please note that deleting any CircYOUity Apps, or any third party apps to which your CircYOUity account is connected, will not delete your CircYOUity account. Similarly, if you delete a third party app that is connected to your CircYOUity account over our API, this will not necessarily delete all data about your CircYOUity activity from within that third party app. You will need to refer to the app provider’s terms of use and privacy policy to find out how to delete data about your CircYOUity activity from that third party app.

  • Managing Device Settings

    • On your mobile device, enable the “Limit Ad Tracking” setting in your iOS phone’s settings, or the setting to “Opt out of Ads Personalization” in your Android phone’s settings. To opt-out of location tracking when using our Apps, you can use the settings of your device. You can disable mobile analytics and bug reporting through these same settings as well.

  • Managing Browser Settings

    • To control cookies, you can modify your settings in most web browsers to accept or deny cookies or to request your permission each time a site attempts to set a cookie. You can also manually delete previously stored cookies at any time. Please note that if you choose to block cookies, doing so may impair the Platform or prevent certain elements of it from functioning.

  • Additional Choices and Controls

Exercising Your Rights

In some jurisdictions, including the EU/EEA, you may exercise any of the rights described in this section through the Help. Please note that we may ask you to verify your identity before taking further action on your request.

  • Data Access and Portability

    • You may be entitled to request copies of your personal information held by us. While a lot of the personal information you provide to us can be accessed in your account Settings, you may also be entitled to request copies of personal information you have provided to us in machine-readable format.

  • Change or Correct Data

    • Where you cannot update data yourself through an account, you have the right to ask us to correct change, update or rectify your data.

  • Data Retention and Deletion

    • We generally retain data for as long as your account is in existence or as needed to provide the Platform. However, specific retention times can vary based on context of the processing we perform and on our legal obligations.

    • You have the right to ask us to delete all or some of the personal data we hold about you. If you have an account, you can also delete your account through the Settings at any time as described below.

    • We may need to retain some of your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations, or where we have a legitimate interest in doing so (e.g. to prevent fraud and abuse and maintain and enhance security).

  • Objection to Processing

    • You may object to processing your personal information in some circumstances (in particular, where we don’t have to process the information to meet a contractual or other legal requirement, or where we are using the information for direct marketing).

    • If you object to such processing CircYOUity will no longer process your personal information for these purposes unless we can demonstrate compelling legitimate grounds for such processing or such processing is required for the establishment, exercise or defense of legal claims or obligations.

    • Where your personal information is processed for direct marketing purposes, you may, under certain circumstances, ask CircYOUity to cease processing your data for these direct marketing purposes.

  • Restriction of Processing

    • Under certain circumstances, you may have the right to limit the ways in which we use your personal information.

  • Withdrawing Consent

    • Where you provide consent to the processing of your personal information by CircYOUity, you may withdraw your consent at any time by changing your account Settings or by sending a communication to CircYOUity specifying the specific consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.

Lodging Complaints

You have the right to lodge complaints about the data processing activities carried out by CircYOUity before a competent data protection authority.

Contact Information

If you have questions or complaints about this Privacy Policy or our practices, please contact our Data Protection Officer by email at [email protected].

Changes to this Privacy Policy

We may update this Privacy Policy from time to time in our sole discretion. If we make changes to this Privacy Policy, we will post the revised Privacy Policy on the Platform and update the “Last Amended” date below. Please be sure to periodically check this page to ensure that you are aware of any changes to this Privacy Policy. Any material changes to this Privacy Policy will be communicated to registered users by a notification to their account and/or by posting a notice of the change on the Website. Your continued access to or use of the Platform after the effective date of such changes will be subject to the revised Privacy Policy.

Last Amended: 25 May 2018

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