CIRCLEME PRIVACY POLICY

Date of Last Revision: 24 MAY 2018
Previous Version (15 NOVEMBER 2014)
Welcome to CircleMe’s privacy policy. Exa Futures (our company, owner of the CircleMe platform) is very well aware of the importance of data protection and has great respect for your privacy. We will do all we can to protect your personal data and we commit to be fully transparent on the use of your data.
We know that these documents might be a bit lengthy and result boring for many, but it is actually very important that you read them fully. Reason being that in this page we will clarify how and why we use your data and the rights you have regarding privacy. If, after reading this document, you still have some doubts or questions, please feel free to write to us at any moment at privacy@circleme.com.
We can also provide you with historical versions of the privacy policies we implemented, and you will always find a link in this page to the previous policy in effect before this one (see link above).
CircleMe was created to make sure anyone could 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 in a private or social setting. 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.

This privacy policy covers all of CircleMe. By registering and accessing (i.e., using) CircleMe, you agree to our privacy practices outlined below.
LET’S START SIMPLE!
We know that reading these documents can be difficult, so here we try to make the following sections a bit more easy to comprehend (you can then read below for further details):
Hope these points helped get you a clear view of who we are and how we care about your personal data. For details on our Privacy Policy, please continue reading below.
OUR POLICY TOWARDS CHILDREN
Our Services are not directed to people under 16. 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 16. If we become aware that a child under 16 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, and you still want to register, 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 https://circleme.com (https://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. We will request for such authorization at the moment of registration, with an “Opt In” process, so that you can actively confirm that you’ll be ok with this method of communication. Furthermore (and in the future, would you change your preferences), you may opt out of such emails from the Settings page on CircleMe (https://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 (we will do so only if strictly necessary, as for example in the case of a security breach or similar event). 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 (unless your contact or you expressively request the deletion).
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 “interest 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 (i.e., “likes”) or “to-do” activities (these 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.
We encourage you to keep your personal information up-to-date so that we can serve you better and contact you if needed. You will be able to update your personal information through the web and the mobile apps, through dedicated editing features (such as the ones present in the “Settings” section of 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.
DATA RETENTION
We will only keep your data for as long as needed to fulfill the purpose we collected it for (which is related to CircleMe’s service itself, or other accounting, legal or reporting requirements).
Different type of data will be subject to different retention periods. While by law we need to keep some data for longer time periods, we commit to keep data related to your account for no more than ten years since you used our services.
In some specific cases we may anonymise your personal data (so that it can no longer be associated with you) for research, aggregated data analysis or statistical purposes in which case we may use this information indefinitely without further notice to you.
At any moment, you may request to delete the data related to your account, as per the “Deleting Your Account” section below.
DELETING YOUR ACCOUNT
We provide you with a way to either deactivate your account, or permanently delete it.
If you decide to “deactivate” your account, all the personal data related to the account will remain available in our systems, but none of it will be visible to other users or to the rest of the web and partners. The reason to enable the function of “deactivation” of an account is to give the opportunity to a person to ‘take a pause’ from the CircleMe platform and evaluate the option of deletion of the account. Would the person want to come back to CircleMe and reactivate the account (and all its related data), it will be as simple as logging into the system again.
If the person registered to CircleMe wants to permanently delete their account, they can do so by writing to our staff at support@circleme.com (the email must be received from the email address associated to the account to be deleted). In this case, CircleMe will delete all personal information related to that account. We will do our best to delete the account within 48 hours from the receipt of the request. Please note that 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 (and in no way will be traceable back to you).
YOUR RIGHTS
Would the General Data Protection Regulation (i.e., GDPR - EU2016/679 [Directive 95/46/EC]) apply to you (in case you reside in the European Union), you have the following rights in relation to your personal data:
These rights are subject to certain rules around when you can exercise them. We suggest you to visit the EU site “Access to European Union law” [Link: https://eur-lex.europa.eu/] for details.
If you wish to exercise any of the rights set out above, please contact us at privacy@circleme.com.
You will not have to pay a fee to access your personal data or to exercise any of the other rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one week. Occasionally it may take us longer than a week if your request is particularly complex or you have made multiple requests. In this case, we will notify you and keep you updated.
We have appointed a Chief Data Officer (CDO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the CDO using the details in our “Contact” section below.
You have the right to file a complain with your local Information Commissioner authority. Having said this, we would really be happy to help you and deal with your concern before you file for the complain. Please give us a chance to help you, and we will go above and beyond what is needed to make you happy.
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) and the General Data Protection Regulation (GDPR) 2016/679 (Directive 95/46/EC), 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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