CIRCLEME PRIVACY POLICY

Date of Last Revision: 15 November 2014
Previous Version (30 OCTOBER 2013)
CircleMe was created to make sure anyone can enjoy in real life the things that s/he is interested in. CircleMe is both a management tool for all the things you like, and a way to engage and share all these things. For the system to work appropriately, some personal information is required by the system and will be shared with other individuals. These privacy policies are designed to help you understand how we specifically collect, use and disclose your information.
For any queries, doubts or comments, please reach out to us at privacy@circleme.com. This privacy policy covers all of CircleMe. By using or accessing CircleMe, you agree to our privacy practices outlined below.
OUR POLICY TOWARDS CHILDREN
Our Services are not directed to people under 13. If you become aware that your child has provided us with personal information without your consent, please contact us at privacy@circleme.com. We do not knowingly collect personal information from children under 13. If we become aware that a child under 13 has provided us with personal information, we take steps to remove such information and terminate the child's account.
WHAT DOES THIS PRIVACY POLICY COVER?
This Privacy Policy covers CircleMe's treatment of personal information that CircleMe collects while you are on the Site and when you use the Services. This policy also covers CircleMe's treatment of any personal information that CircleMe's business partners share with CircleMe. This policy does not apply to the practices of third parties that CircleMe does not own or control, including but not limited to third party services you access though CircleMe, third party services using CircleMe’s set of API’s, or to individuals that CircleMe does not employ or manage. As our Services integrates with third-party sites, such as Facebook and other sites and social networks, we assume that you are already aware of their own Privacy Policies when using CircleMe and when you allow CircleMe to interact with these sites on your behalf.
INFORMATION COLLECTION & USE
By visiting and interacting with CircleMe or any of CircleMe Services which includes a link to this privacy policy (i.e., CircleMe and Partner Sites, each CircleMe Site), you provide us three types of information: Personal Information (i.e., information that you purposely disclose or that you authorize to be disclosed on your behalf); Content and User Contributed Content (as defined in the CircleMe Terms of Service); and Automatic Information (e.g. your IP address and browser type).
PERSONAL INFORMATION
Information provided at registration and through the user of the CircleMe application (web or mobile). In order to access certain functionality of the Service, you will be required to become a registered user. When you register with us at a CircleMe Site, we collect your name, email address, user name, as well as some other personal information that you may choose to provide to us (e.g., personal picture, location/ IP address, Facebook ‘likes’ preferences, etc). Furthermore, if you connect to CircleMe via a third-party website (e.g., using Facebook connect), CircleMe will receive and might store any information that is made available by such third-party website.

To serve a valuable service to all its users, CircleMe allows to search for other users through their first name, last name or username. This information will remain public. Additionally, to facilitate browsing and search functionality, CircleMe does not allow to set privacy on the personal picture (thumbnail and background picture): if you do not feel comfortable in showing these to other users, we advise you to not publish any.

While using the CircleMe service, you might express preferences for items present in the system (i.e., “like”) and you might mark some of the items as worth evaluating further (i.e., “to-do”). Any CircleMe ‘like’ and ‘to-do’ could potentially be visible to other users, within or outside of CircleMe. You can establish who can view these items by determining the preferred settings in the Settings page on www.circleme.com (www.circleme.com/settings). We may occasionally use your name and email address to send you notifications regarding new services offered by CircleMe that we think you may find valuable. We may send you service-related announcements from time to time through the general operation of the Service.

For instance, if a user sends you a new message or a new suggestion of an item, you may receive an email alerting you of that fact. Generally, you may opt out of such emails from the Settings page on CircleMe (http://www.circleme.com/settings), though we reserve the right to send you important notices about your account even if you opt out of all voluntary email notifications. You can adjust what information is presented back to you and other CircleMe users by adding and removing content from your profile or by adjusting the settings in your CircleMe profile.

Sending invitations and suggestions from CircleMe. If you choose to use our invitation or suggestion services to invite a friend to join CircleMe or to suggest a potential item of interest to a person you know, we will ask you for information needed to send this invitation/message, such as your contact's email address. We will use such information to send your contact(s) an email and reminder e-mails in your name inviting him or her to visit www.circleme.com, to allow you to see invitations you have sent, and to track the success of our referral program. Your contact may unsubscribe through the link provided with such correspondence, which will prevent your contact from receiving further correspondence, but we may retain your contact's information in our database.

Contacting us through a CircleMe Site. If you contact us by email through the site, we may keep a record of your contact information and correspondence and will use your email and correspondence if we decide to respond to you.
USER CONTRIBUTED CONTENT
You can create or upload to CircleMe different kinds of content, including text, messages, posts, html, URLs, images, video and other. Furthermore, any user in CircleMe can contribute to the site’s content database by creating items that are not present in its database. This content is the basis through which CircleMe provide its Service, and can be resubmitted to you and to other CircleMe users. This content is collected and retained to be part of an increased user experience.
AUTOMATIC INFORMATION
We may receive and store certain types of information whenever you interact with us. CircleMe may automatically receive and record information on our server logs from your browser including your IP address, CircleMe cookie information, and the information you request. CircleMe may use this traffic data to help diagnose problems with its server, analyze trends and administer the Site and Services. Our service may automatically collect usage information, such as the numbers and frequency of visitors to our Site and Services and their components.

CircleMe may use this data in aggregate form, that is, as a statistical measure, but not in a manner that would identify you personally. This type of aggregate data may enable us to figure out how often customers use parts of the Site and Services, so we can make the Site and Services appealing to as many users as possible. As part of this use of information, we may provide aggregate information, not information about you personally, to our partners about how our users, collectively, use our Site and Services. If we share this type of statistical data, we do this so that our partners can understand how often people use their areas of our Site and Service, and can therefore provide you with an optimal CircleMe experience.

We use your user contributed Content, Personal Information, and Measured Data and the combination thereof to provide, maintain, and improve our Services, to better understand how you interact with CircleMe, to provide personalized features of the Service, to monitor your use and aggregate users' use of CircleMe, to administer your inquiries, and to enforce our (or our partners' or users') rights. As one example, as you use a CircleMe Site, your profile may be automatically updated to reflect your use of such site including what items you like, which things you might be interested in evaluating, how similar you might be to other users of the site, your expertise in specific fields, your overall influence in the community (i.e. ‘Reach Score’), and other actions you take.

We also use your user contributed Content, Measured Data, and the aggregated Personal Information of the members of CircleMe or a specific group or demographic, and any combination of such information, to deliver custom content and advertising that may be of interest to you.
HOW WILL CIRCLEME USE YOUR INFORMATION?
  1. To manage the service: We use the information we collect to provide our services and features to you, to measure and improve those services and features, and to provide you with customer support. We use the information to prevent potentially illegal activities, and to enforce our CircleMe Terms of Service. We also use a variety of technological systems to detect and address anomalous activity and screen content to prevent abuse such as spam. These efforts may on occasion result in a temporary or permanent suspension or termination of some functions for some users.
  2. To contact you. We may contact you with service-related announcements from time to time. You may opt out of all communications except essential updates on your Account Information page.
  3. To make you suggestions: our technology automatically uses some of the information you provided to spot and suggest to you items of interest that you might want to ‘like’ or mark as a ‘to-do’.
  4. To find “neighbors”: our technology automatically uses some of the information you provided to find other CircleMe users who might be interesting for you to give a look at, since they might share with you same interests or ‘to-do’ activities (there are potential “like-minded” people).
WILL CIRCLEME SHARE ANY OF THE INFORMATION IT RECEIVES?
Information about our users is important to our business. We neither rent nor sell your personal information to anyone. We share information related to your account only as described below.
INFORMATION SHARING AND DISCLOSURE
We do not disclose your private information except in the limited circumstances described here.
Your Consent: We may share or disclose your information with your consent, such as when you use a third party web client or a service using any of our Application Programming Interfaces (i.e, API’s) to access your CircleMe account.

Service Providers: We engage certain trusted third parties (e.g., Google Analytics, etc.) to perform functions and provide services to us. We may share some of your personal information with these third parties, but only to the extent necessary to perform these functions and provide such services, and only pursuant to obligations mirroring the protections of this privacy policy. Law and Harm: We may disclose your information if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect CircleMe's rights or property.

Business Transfers: In the event that CircleMe is involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be sold or transferred as part of that transaction. The promises in this privacy policy will apply to your information as transferred to the new entity.

Non-Private or Non-Personal Information: We may share or disclose your non-private, aggregated or otherwise non-personal information, such as the number of users who clicked on a particular link (even if only one did).
MODIFYING YOUR PERSONAL INFORMATION
If you are a registered user of our Services, we provide you with tools to access or modify the personal information you provided to us and associated with your account.
DISCONNECTING FROM OTHER SERVICES (API’S)
We provide you with an easy way to disconnect your CircleMe account to any other service that initially you connected your account to, through CircleMe’s API’s.In this case, the third-party service using CircleMe’s API’s will not be able to access any of your CircleMe data.
DELETING YOUR ACCOUNT
We provide you with a way to delete your account. In this case, CircleMe will delete all personal information related to that account. The comments, reviews, and related activities on CircleMe for that user will not be deleted, but the content generated by this user will be associated with an anonymous source.
CHANGES TO THIS POLICY
We may revise this Privacy Policy from time to time. The most current version of the policy will govern our use of your information and will always be at http://www.circleme.com/privacy. If we make a change to this policy that, in our sole discretion, is material, we will notify you via an e-mail to the email associated with your account. By continuing to access or use the Services after those changes become effective, you agree to be bound by the revised Privacy Policy.
CONTACT
For the purpose of the Data Protection Act 1998 (the Act), the data controller is Exa Futures Srl and for any physical correspondence, you can reach us at:
Exa Futures Srl
Privacy Team
via Durini 26
20122 Milano (MI)
Italy
Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to privacy@circleme.com.


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