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Privacy Policy

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Introduction

"Circle Up" highly values the privacy and confidentiality of your personal information. We are fully committed to safeguarding this information through appropriate measures and utilizing it only for the purposes defined in this Privacy Policy. This document will provide you with a comprehensive understanding of the collection and processing of your personal data, how we protect it, its utilization, and the rights granted to you concerning your personal data.

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This Privacy Policy ('Policy') outlines how Circle Up collects and processes your personal information, both online and offline, in accordance with the General Data Protection Regulation (2016/679) and the applicable Data Protection Laws of the Republic of Cyprus ('the Law').

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Definitions

  • Data Controller: The entity responsible for determining when, why, and how Personal Data is processed and implementing appropriate technical and organizational measures to comply with the Law.

  • Data Protection Officer: The individual formally appointed to ensure compliance with data protection responsibilities and obligations according to the Law.

  • Data Subject: An identifiable natural person about whom we hold Personal Data.

  • European Economic Area (EEA): Comprises EU countries, Iceland, Liechtenstein, and Norway.

  • Personal Data: Data about a Data Subject that can identify them directly or indirectly.

  • Processing: Any operation or set of operations performed on Personal Data, including collection, recording, organization, storage, alteration, retrieval, use, disclosure, and more.

  • Special Categories of Personal Data: Information revealing racial or ethnic origin, political opinions, religious beliefs, health conditions, and more.

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For the purposes of this Policy, Personal Data includes Special Categories of Personal Data.

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Information We Collect

We collect the following types of information based on the services you request or use:

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  • Information provided when submitting the 'Sign Up To Newsletters' form or contacting us through our website (e.g., Name, Email Address).

  • Information gathered from your use of our website or through Google Analytics (e.g., IP Address, Mobile Device Id, Referral Source, Page Views).

  • Information gathered from transactions and agreements between us for providing our services (e.g., Company Details, Name, Address, ID).

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Legal Basis for Processing Your Personal Data

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As Data Controllers, we may collect and process your Personal Data for the following purposes:

  • Legal obligations: When processing Personal Data is required by applicable laws.

  • Consent: When you have given consent for specific processing purposes (e.g., requests made on our website, email notifications).

  • Legitimate Interests: When Personal Data is necessary to execute, promote, assess, and advance our services, subject to the Data Subject's interests and rights.

  • Contractual Obligations: For the commencement and continuation of services between us and you as a client or service provider.

Recipient of Your Personal Data

Your Personal Data may be shared with or made accessible to:

  • Employees, affiliates, or partners requiring access for specific purposes.

  • Service providers, including IT service providers supporting our services.

  • Payment Service Providers.

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Without your consent, Personal Data will not be disclosed to any Third Party, except when required by legislation, regulation, or governmental request.

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Retention of Personal Data

We retain your Personal Data for up to seven years after your relationship with us ends or when such retention no longer serves the purposes for which it was collected or is legally required.

Protection of Personal Data

We employ administrative, physical, and technical measures to secure your Personal Data from unauthorized access, collection, use, damage, loss, disclosure, copying, or similar risks.

 

Your Rights

You have the following rights in relation to your Personal Data:

  • Right to access: Request a copy of your Personal Data.

  • Right to rectification: Request correction or update of your Personal Data.

  • Right to data portability: Request transfer of your Personal Data.

  • Right to erasure: Request deletion of your Personal Data (subject to legal or administrative requirements).

  • Right to restrict processing: Request restrictions on the use of your Personal Data.

  • Right to object: Object to the collection and use of your Personal Data.

To exercise these rights, contact our Data Protection Officer using the provided contact details.

 

Effect of Policy and Changes

This Policy may be modified periodically without prior notice. Please review our website's Policy page regularly to stay informed of any updates.

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Cookies Policy

Our website uses cookies to enhance your browsing experience. These small files store information about your interactions and usage of our website. You can manage cookie settings in your browser to block or disable cookies if desired.

We also collect non-personal information such as browser types, search terms, traffic referrals, and links to improve website performance. This data is analyzed in aggregate and does not contain personally identifiable information.

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