How and why we use 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.
Circle is committed to protecting the privacy of visitors to our website, subscribers to our newsletters, and those providing contact information. In addition, Circle is opposed to unauthorised commercial e-mail delivery, otherwise known as spam. Please read the following Privacy and Marketing Policy to understand how your personal information is treated. From time to time, Circle may offer new information or services that may affect this policy. If you have any questions or concerns regarding this Privacy and Marketing Policy, please send an e-mail to firstname.lastname@example.org.
The following policy (“Privacy and Marketing Policy”) sets forth Circle’s policy with respect to information, including personally identifiable data (“Personal Data”) and other information, Circle collects from visitors to our website located at https://www.circleit,co.uk (the “Website”).
This Privacy and Marketing Policy does not apply to information of any kind that we collect by means (including offline means) or from sources other than those specified herein.
What information do we collect and how is it used?
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.
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.
Does Circle share my information?
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.
As part of The Arrow Group, we may share data between branches of the business in order to effectively carry out our everyday business functions and provide the best level of service and information.
The Arrow Group, including Arrow Business Communications Limited and Arrow Business Communications (Scotland) Limited (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, contact number, address, email address, date of birth and IP addresses. The sharing of this data will be in line with the legitimate interest contacts may have in the information the Group is providing. For any marketing communications, recipients can unsubscribe and request to have their data removed from marketing lists at any time.
Tracking: Circle uses various marketing tools that help us create a better user experience for people visiting our site. These tools allow us to look at aggregated data such as scrolling patterns, clicks and allow us to run tests to determine which pages result in the best actions. However, your personally identifiable information is not used by any of these tools.
Remarketing: Circle may use remarketing tracking cookies and conversion pixels from vendors such as Google and LinkedIn to present special offers to you for our products or services over the Google Content Network and via social networks. This means you may see an ad for one of our products or services as a result of visiting our website.
Your personal information is not shared with any other third-party applications.
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.
Other types of data
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.
Rights related to your personal data
Please note that while any amendments, corrections or deletions will be reflected in active user databases (as updated with a reasonable period of time), we may retain all Personal Data for backups, archiving, prevention of fraud and abuse, analytics, and satisfaction of other legal obligations we reasonably believe applicable.
We may retain your Personal Data to comply with laws, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our contracts, and take other actions otherwise permitted by law.
Please contact us at email@example.com to submit a request or obtain information regarding any of the above.
Opt-out: You may opt-out of future e-mail communications by following the unsubscribe links in our e-mails. You may also notify us at firstname.lastname@example.org to be removed from our mailing list.
Access: You may access the personal information we have about you by submitting a request to email@example.com
Amend: You may contact us at firstname.lastname@example.org to amend or update your personal information.
Sensitive personal information
Unless you choose to provide it to us, we do not collect sensitive personal information from you using the Website.
and we will use our best efforts to promptly remove such information from our records.
Circle is strongly opposed to spam. We will only send e-mails that we deem to be in line with the individual’s interests which we base of either engagement with previous content, the services they have with Circle or subscription to our newsletters. Examples may include:
- Opt-in subscribers to the Circle Newsletter
- Users that complete a contact form
- All communication will be related and relevant to what you have requested
- Submitted contacts details around specific content, products or services
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.
How do I contact Circle?
If you have any further questions or comments regarding the Circle website or this Privacy and Marketing Policy, you may contact email@example.com.
Changes to Circle's policy