This privacy notice sets out, in line with GDPR, the types of data that we collect and hold. It also sets out how we use that information, how long we keep it for and other relevant information about your data.
This notice applies to our current customers and suppliers, our former customers and suppliers and our prospective customers and suppliers.
We have separate privacy notices for:
- Job applicants, which will be issued to anyone applying for a job with us
- Employees, which will be issued to new employees with their offer of employment
Data Controller Details
The Company is a data controller, meaning that it determines the processes to be used when using your personal data.
Our contact details are as follows:
- Address: Circle IT Solutions, Brook House, 2 Lime Tree Court, Mulberry Drive, Cardiff Gate Business Park, CF23 8AB
- Telephone: 0330 333 8001
- E-Mail: firstname.lastname@example.org
Data Protection Principles
In relation to personal data, we will:
- Process it fairly, lawfully and in a clear, transparent way
- Collect data only for reasons that we find proper for the course of providing our services to customers or engaging the services of suppliers, in ways that have been explained to you
- Only use it in the way that we have told you about
- Ensure it is correct and up to date
- Keep data for only as long as we need it
- Process it in a way that ensures it will not be used for anything that you are not aware of or have consented to (as appropriate), lost or destroyed
Types of Data We Process
We hold and process the personal details, including their name, address, email address and phone numbers of:
- Our current customers and suppliers
- Our prospective customers and suppliers
- Our former customers and suppliers
How and why we use your personal data
Marketing the services provided by us and the members of the Arrow Group and those of selected third parties to:
- existing and former customers; and
- third parties who have previously expressed an interest in our services.
in each case for the purposes of our legitimate interests, ie to promote the Arrow business to existing and former customers and third parties that may be interested in our services.
How We Collect Data and how it is used
Data relating to our current, former and prospective customers and suppliers is collected:
- Directly from the customer or supplier, or
- From third parties, such as referrals or recommendations from existing customers and suppliers, former customers and suppliers or other professional acquaintances.
- Through marketing lead generation activity
Personal data is kept within the Company’s IT systems and Marketing CRM system.
Analytics: Our website uses 'analytics' cookies for the sole purpose of tracking the performance of our website and understanding more about what is of interest to our website's visitors.
- Store visitors’ preferences;
- Record user-specific information on what pages users access or visit;
- Ensure that visitors are not repeatedly sent the same banner ads;
- Customise our content based on visitors’ browser type or other information that the visitor sends.
Information You Voluntarily Submit to the Website
We collect Personal Data from you when you voluntarily provide such information, such as when you contact us with inquiries, register for access to the Website or purchase products or services from the Website. Personal Data may include, but is not limited to, the below:
- Your name and email address
- Your website URL and name
- Company name
- Phone number (where relevant and provided)
Automatically-Collected Information: We automatically collect certain information about you and the device with which you access Circle. For example, when you access our website, we will log your IP address, operating system type, browser type, referring website, pages you viewed, and the dates/times when you accessed the website. We may also collect information about actions you take when using the website, such as links clicked.
Non-Identifiable Data: When you interact with us through the Website, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. We may store such information or such information may be included in databases owned and maintained by our affiliates, agents, or service providers. The Website may use such information and pool it with other information to track, for example, the total number of visitors to our Website, the number of visitors to each page of our Website, and the domain names of our visitors’ Internet service providers. It is important to note that no Personal Data is available or used in this process.
Aggregated Personal Data: In an ongoing effort to better understand and serve the users of our website, Circle my conduct research on its customer demographics, interests and behaviour based on the Personal Data and other information provided to us. This research may be compiled and analysed. This information does not identify you personally.
Why We Process Data
The law on data protection allows us to process your data for certain reasons only:
- In order to perform the contract that we are party to
- In order to carry out legally required duties
- In order for us to carry out our legitimate interests
- To protect your interests and
- Where something is done in the public interest.
All of the processing carried out by us falls into one of these permitted reasons. Generally, we will rely on the first three reasons set out above to process your data.
For example, we need to collect and process the personal data of customers and suppliers in order to perform the contract that we are party to with them and to maintain accurate accounting records in order to carry out our legally required duties.
We also collect data so that we can carry out activities which are in the legitimate interests of the Company. We have set these out below:
- Contacting prospective customers and suppliers
- Tracking the performance of our website and understanding more about what is of interest to our website visitors
- Dealing with legal claims made against us or bringing legal claims against others
- Preventing fraud
How your personal information may be used
Circle may use your personal information in the following ways:
- To operate and maintain the website;
- To create your account, identify you as a user of the website, and customise the website to your account;
- To send you promotional information, such as newsletters. Each e-mail newsletter will provide information on how to opt-out of future mailings by unsubscribing;
- To send you administrative communications, such as administrative e-mails, confirmation e-mails, technical notices, updates on policies, or security alerts;
- To respond to your comments or inquiries;
- To provide you with user support;
- To track and measure website performance;
- To protect, investigate, and deter against unauthorised or illegal activity;
- To review the effectiveness of our marketing programs and analyse other general demographic trends;
- To notify you of new information or services that may be of interest to you; or,
- To send promotional materials.
Legal bases for processing data under the general data protection regulation (“GDPR”)
Below are the types of lawful basis that we will rely on to process your Personal Data:
- Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personal Data for our legitimate interests. We do not use your Personal Data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law).
- Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
- Comply with a legal or regulatory obligation means processing your Personal Data where it is necessary for compliance with a legal or regulatory obligation that we are subject.
- Consent means where you have consented to a certain use of your Personal Data.
Special Categories of Data
We know that we must process special categories of data in accordance with more stringent guidelines, however we do not and will not process special category data relating to our customers or suppliers.
Special categories of data are data relating to:
- Criminal convictions and offences
- Sex life
- Sexual orientation
- Ethnic origin
- Political opinion
- Trade union membership and
- Genetic and biometric data.
If You Do Not Provide Data To Us
One of the reasons for processing your data is to allow us to carry out our duties in line with a contract that exists between us. If you do not provide us with the data needed to do this, we may be unable to perform those duties.
Agents, Consultants, and Related Third Parties: Circle, like many businesses, sometimes hires other companies to perform certain marketing functions and campaigns. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function.
Data may be shared with colleagues within the Group* where it is necessary for them to undertake their duties.
We may share data with:
- Autotask for the storage of customer contact information and processing orders and invoices
- Our e-mail provider, Mimecast and Microsoft Office 365
- Active Campaign for the storage of customer contact information in the form of name and email addresses to contact customers for feedback on our service
- Microsoft Office 365 SharePoint for the storage of project schedules and project plans
- IT Glue for system configuration for supporting customers IT systems
- Autotask Endpoint Management for the processing of system health information for our customers to respond to proactive alerts
- Our legal advisors and HM Courts and Tribunal Services for the defence of any legal claims made against us, or in bringing claims against customers, suppliers or third parties;
We may also share data for other reasons to comply with a legal obligation upon us.
* The term 'Group' is used to describe the group of organisations within Arrow Business Communications - The Arrow Group, including Arrow Business Communications Limited and Arrow Business Communications (Scotland) Limited and all affiliates and subsidiaries (hereinafter referred to as the “Group”) needs to collect personal information to effectively carry out our everyday business functions and activities and to provide the products and services defined by our business type. Such data is collected from employees, customers, suppliers and clients and includes (but is not limited to), name, address, email address, date of birth, IP address, identification numbers, private and confidential information, sensitive information and bank/credit card details.
Marketing use of data
We will use your personal data to send you updates (by email, text message, telephone or post) about the products and/or services of the Arrow Group, including exclusive offers, promotions or new products and/or services.
We have a legitimate interest in using your personal data for marketing purposes (see above ‘How and why we use your personal data’). This means we do not usually need your consent to send you marketing information. If we change our marketing approach in the future so that consent is needed, we will ask for this separately and clearly.
You have the right to opt-out of receiving marketing communications at any time by:
- contacting us at email@example.com;
- using the ‘unsubscribe’ link in emails or ‘STOP’ number in texts
We may ask you to confirm or update your marketing preferences if you ask us to provide further products and/or services in the future, or if there are changes in the law, regulation, or the structure of our business.
We may disclose your personal data to:
- other members of the Arrow Group; and
- third parties in the event that we sell or transfer any business or assets, in which case we may disclose personal data we hold about you to the prospective and actual buyer of such business or assets.
Where we disclose your data to other members of the Arrow Group, those other group members may contact you and send you marketing communications about products and services which may be of interest to you.
If you have consented to receive marketing communications from the Arrow Group (or, if you are a corporate subscriber, you have not objected to us sending you marketing communications), you have the right to ask us to stop sending you marketing communications at any time, although that will not affect the lawfulness of such processing before consent has been withdrawn or your objection has been received. To withdraw your consent or to object to receiving marketing communications, please contact us at firstname.lastname@example.org or follow the unsubscribe instructions included in each electronic marketing communication. Once we have received notification that you no longer wish to receive marketing from us, we will no longer process your information for this purpose, unless we have another legitimate basis for doing so in law.
We are aware of the requirement to ensure data is protected against accidental loss or disclosure, destruction and abuse. We have implemented processes to guard against such.
Where we share data with third parties, we provide written instructions to them to ensure that data are held securely and in line with GDPR requirements. Third parties must implement appropriate technical and organisational measures to ensure the security of data.
Automated Decision Making
In line with data protection principles, we only keep your data for as long as we need it for. Retention periods can vary depending on why we need your data and are set out in our Data Retention Schedule which is available from email@example.com
Your Rights in Relation to Data
The law on data protection gives you certain rights in relation to the data we hold on you. These are:
- The right to be informed. This means that we must tell you how we use your data, and this is the purpose of this privacy notice
- The right of access. You have the right to access the data that we hold on you. To do so, you should make a subject access request
- The right for any inaccuracies to be corrected. If any data that we hold about you is incomplete or inaccurate, you are able to require us to correct it
- The right to have information deleted. If you would like us to stop processing your data, you have the right to ask us to delete it from our systems where you believe there is no reason for us to continue processing it
- The right to restrict the processing of the data. For example, if you believe the data we hold is incorrect, we will stop processing the data (whilst still holding it) until we have ensured that the data is correct
- The right to portability. You may transfer the data that we hold on you for your own purposes
- The right to object to the inclusion of any information. You have the right to object to the way we use your data where we are using it for our legitimate interests
- The right to regulate any automated decision-making and profiling of personal data. You have a right not to be subject to automated decision making in way that adversely affects your legal rights.
Where you have provided consent to our use of your data, you also have the unrestricted right to withdraw that consent at any time. Withdrawing your consent means that we will stop processing the data that you had previously given us consent to use. There will be no consequences for withdrawing your consent. However, in some cases, we may continue to use the data where so permitted by having a legitimate reason for doing so such as contractual obligations.
If you wish to exercise any of the rights explained above, please contact firstname.lastname@example.org.
Circle contains links to other sites. Please be aware that Circle is not responsible for the privacy practices or the content of such other sites. We encourage our users to be aware when they leave our site to read the privacy and spam policies of each and every website that collects personally identifiable information. This Privacy and Marketing Policy applies solely to information collected by Circle.
If you send us an email with questions or comments, we may use your personally identifiable information to respond to your questions or comments, and we may save your questions or comments for future reference. For security reasons, we do not recommend that you send non-public personal information, such as passwords, social security numbers, or bank account information, to us by email. You may “opt-out” of receiving future commercial email communications from us by clicking the “unsubscribe” link included at the bottom of most emails we send, however, we reserve the right to send you transactional emails such as customer service communications or communications with your Account Manager.
Changes to Circle's policy
Making a Complaint
The supervisory authority in the UK for data protection matters is the Information Commissioner (ICO). If you think your data protection rights have been breached in any way by us, you are able to make a complaint to the ICO.
Data Protection Manager
The Company is not required to appoint a Data Protection Officer. All correspondence in relation to GDPR is to be addressed to email@example.com.