Privacy & Cookies

CIRCLE LAB PRIVACY AND COOKIES POLICY

Circle Lab’s Privacy & Cookies Policy (“Privacy Policy”) was last updated on 28 August, 2018.

Circle Economy does not sell or rent your Personal Information (later defined) to third parties without your explicit consent. Please read this Privacy Policy to learn more about the ways in which Circle Economy uses and protects your Personal Information.

This Privacy Policy applies to the Circle Economy content on the internet site located at www.circle-lab.com along with any related websites, networks, and other services provided by Circle Economy (collectively the “Platform” or “Circle Lab”). By using the Platform you agree to be bound by the terms and conditions of this Privacy Policy. Capitalized terms not defined in the Privacy Policy have the meanings ascribed to them in the Terms and Conditions of Use (the "TOU"). If you do not agree to the Privacy Policy or the TOU please do not use or access the Platform.

This Privacy Policy describes the information we collect from you and what may happen to that information. By accepting the Privacy Policy, you expressly consent to Circle Lab’s use and disclosure of your Personal Information in accordance with this Privacy Policy.

This Privacy Policy may be updated from time to time, so we advise visitors to consult it regularly for changes. We will notify you of any material changes by prominently posting notice of the new Privacy Policy to the Platform and/or by sending you an email to the last email address provided to us. You are advised to consult this Privacy Policy regularly for any changes.

As used in this Privacy Policy, the terms "using" and "processing" information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the Netherlands or internationally.


INFORMATION COLLECTED
Our primary purpose in collecting your first name, email address, age, interests, username, and password when you register to the Platform (the “Login Information”) is to:  (i) provide you with a safe, smooth, and efficient experience and to adjust our products and services, (ii) be able to contact you in connection with any Contribution that you submit, (iii) administer your account, and (iv) communicate with our Users or schedule any technical work to the Platform with minimal interference. Any information about you that can be used to contact or identify you is personal information ("Personal Information"). We only collect the minimum amount of Personal Information about you that we consider necessary for achieving the aforementioned purposes. Your email address is not displayed publicly on the Platform but it will be displayed to Moderators (as defined in the TOU).
Your Login Information is held within your account called My Profile. This is (i) created when you register on the Platform and (ii) added to at will by you the user. It is each user’s decision as to whether they add additional Personal Information to their My Profile section or upload a photograph/image of themselves and opt to make these visible to Other Users as part of My Profile.

In general, you can browse the Platform without telling us who you are or revealing any Personal Information about yourself. Once you register, create My Profile, or submit a Contribution you are not anonymous to us. As only Users can submit a Contribution on the Platform, if you choose to submit a Contribution prior to registering to the Platform, we will require you to first (i) register with your Login Information thus creating My Profile and if applicable (ii)  agree to any Challenge Rules. All Contributions will be viewable by Other Users of the Platform. You always have the option to not provide information by choosing not to register or submit a Contribution.

If you register and create My Profile, choose to submit Contributions, or post messages on the Platform, we will collect and store that information you provide to us. If you delete your account on the Platform, your user data will be removed from the Platform and your My Profile will be deleted, however your posts and comments may still be visible under the alias “Deleted User.”

If you send us personal correspondence, such as emails or letters, or if Other Users or third parties send us correspondence about your activities or postings on the Platform, we may collect such information into a file specific to you.


USE OF YOUR INFORMATION
We use your Login Information in the file we maintain about you, and other information we obtain from your current and past activities on the Platform to:

Contact you about any Contributions
Contact you with Notifications
Send you suitable Challenges and newsletters
Contact you with feedback surveys
Troubleshoot problems and resolve disputes
Detect and protect us against error, fraud and other criminal activity
Enforce the TOU

We may use your Login Information to analyse customer behaviour and to adjust our products and services accordingly, to ensure that it is relevant; to contact you with information about new features and updates about the Platform and Circle Lab including offering new functionalities, changing the User experience, and updating functionalities; and other information that you may be interested in based on your account details, websites you have visited and the data you have entered into our websites, your online and offline history and your registered use of Circle Economy or other Circle Economy websites.

Further, we regularly conduct research on the level of satisfaction of Users, through the use of feedback surveys. We use your responses to such surveys for quality assessments and to improve your customer experience.

Based on the information above, we can make adjustments to the Platform. We may also adapt our promotions on the basis of our analysis. We may also perform research into market trends through statistical analysis to evaluate and adapt our products and marketing to new developments, but research results are only reported on an aggregated basis.

We may share aggregated information that does not include Login Information and we may otherwise disclose information that does not identify you (“Non-Identifying Information”) and information about your activities on the Platform (“Log Data”) with third-parties for industry analysis, demographic profiling, academic research, and other purposes. Any aggregated information shared in these contexts will not contain your Personal Information.

You agree that we may use your Login Information to contact you. By accepting the TOU, you expressly agree that we may contact you as provided herein.


DISCLOSURE OF YOUR INFORMATION
Circle Economy may disclose information it has collected from you and/or Contributions you have made available on the Platform when it believes in good faith that the law or legal process requires it, or when it is necessary to do so to protect the rights or property of Circle Lab, Challenge Issuers, or others. As a matter of policy, we do not sell or rent any of your Personal Information to third parties without your explicit consent. The following describes some of the ways that your Personal Information may be disclosed in the normal scope of our business and you authorize us to do this for the purposes of the use and operation of the Platform, or any investigations of the information on the Platform.

Challenge Issuer: A Challenge Issuer cannot store or disclose your Personal Information; this can only be done by Circle Economy in compliance with this Privacy Policy. Circle Economy may share information that you have entered in My Profile with a Challenge Issuer to analyze Users’ Contributions for the Challenge Issuer’s own Challenges.

Other Users: When you post Contributions to the Platform, including ideas and comments, certain Personal Information about you, such as your user name, identifying photo, and Profile Content may – and likely will be – displayed on the Platform. More sensitive Personal Information, such as your postal address, e-mail address, phone number, will NOT be displayed on the Platform. Other Users, including Users who come to Circle Lab via a link posted on a third party website, including Third Party Sites, will have access to the publicly displayed information. We are not responsible for privacy practices of the Other Users who will view and use the posted information you choose to make available on or through Circle Lab. You should therefore be mindful of these types of disclosures when selecting a User name or choosing the photograph to use with your account.

Service Providers for Our Operations: We may use third parties, such as Mailchimp and Mandrill, that we refer to as service providers to facilitate or outsource one or more aspects of our business, including as part of our registration process or to facilitate our mailing lists. Therefore we may provide some of your Personal Information directly to these service providers, or this information may come available to them in the course of our business with them. We recommend you review the privacy policies of these service providers.

Other Entities: We may share our data, including Personal Information about you, with our affiliates and subsidiaries. To the extent these entities have access to your information, they will treat it at least as protectively as they treat information they obtain from their users. To the extent allowed by applicable law, these entities follow privacy practices that are no less protective of users than the practices described in this Privacy Policy. Circle Economy may share some or all of your Personal Information, Non-Identifying Data and Log Data with another business entity should we plan to reorganize, spin out, merge with, acquire, or be acquired by that business entity. Should such an event occur, we will require that the new or combined entity follow this Privacy Policy with respect to your Personal Information. If your Personal Information will be used contrary to this Privacy Policy, you will receive prior notice as previously described.

Legal Requests: Circle Economy cooperates with law enforcement inquiries, as well as other third parties to enforce laws and intellectual property rights. Therefore, in response to a verified request by law enforcement or other government officials relating to a criminal investigation or alleged illegal activity, we can disclose Login Information including name and email address, and without limiting the above, in an effort to respect your privacy, we will not otherwise disclose your Personal Information to law enforcement or other government officials without a subpoena, court order or substantially similar legal procedure, except when we believe in good faith that the disclosure of information is necessary to prevent imminent physical harm or financial loss; or to report suspected illegal activity.

Due to the existing regulatory environment, we cannot ensure that all of your private communications and other Personal Information will never be disclosed in ways not otherwise described in this Privacy Policy. By way of example and without limiting the foregoing, we may be forced to disclose your Personal Information to the government or third parties under certain circumstances or third parties may unlawfully intercept or access transmissions or private communications. Therefore, although we use industry standard practices to protect your privacy, we do not promise, and you should not expect, that your Personal Information or private communications will always remain private.


CORRECTING OR DELETING PERSONAL INFORMATION
You agree to maintain and promptly update and keep accurate, current and complete any information provided to Circle Lab as part of My Profile. You can change your username, email address, password, contact and other information by going to My Profile. Your previous Contributions will be associated with the updated information. You may update or correct your profile information and preferences at any time on the Platform or by emailing us at lab@circle-economy.com.

Your personal profile will be made available to Other Users. Be aware that Other Users can object to any content on My Profile if they believe it is damaging or offensive. Your recent Contributions and current and past Challenges, are shown on your My Profile page. 

If you would like us to delete your account record in our system, you are able to do so by contacting us at lab@circle-economy.com with a request to delete your account, providing your username, and entering “Delete my account” in the subject line. We will use commercially reasonable efforts to honor your request. Removal of this content or information from public view does not guarantee complete or comprehensive removal. After your removal request has been honored, we may retain an archived copy of your records as required by law or for legitimate business purposes. We are not required to remove your posted content or information if it has been rendered anonymous or if we are required by law to retain it. Additionally, we do not have control over third parties (e.g., Other Users) who may have copied or reposted this information. If you have included Login Information in online forum postings or in information or communications shared with Other Users, you may not be able to update, correct or delete this information from the Platform.


CONTROL OF YOUR PASSWORD
Upon creating your account, we will send you your Login Information. These personal data enable us to administer your account and enables us to ensure the confidentiality and to maintain the security of your information. We are, for instance, able to change your password for you. We are, however, not able to view your password.

You are responsible for all actions taken with your Login Information. Accordingly, you agree to maintain and safeguard the confidentiality of your Login Information, and to not share your Login Information with any third party. We recommend that you do not disclose your password to any third parties. If you choose to share your username and password or your Personal Information with third parties, you are responsible for all actions taken with your account and therefore you should review that third party’s privacy policy. If you lose control of your password, you may lose substantial control over your Personal Information and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately change your password. If you need help changing your password, please contact lab@circle-economy.com.


OTHER INFORMATION COLLECTORS
Except as expressly stated in the Privacy Policy, this Privacy Policy only addresses the use and disclosure of information we collect from you via the Platform. To the extent that you disclose your information to other parties on our Platform or other sites throughout the internet, different rules may apply to their use or the disclosure of information you disclose to them. Since Circle Economy does not control the privacy policies of third parties, you are subject to the privacy policies of that third party. We encourage you to ask questions before you disclose your Personal Information to others.


SECURITY
Your information is stored on our service provider’s servers in Amsterdam. For more information regarding these services, including the security of the servers, please see Sentia (https://sentia.nl/). These service providers have agreed to maintain the confidentiality, security and integrity of Personal Information collected through the Platform.

We use reasonable physical, procedural, technical and administrative security measures to protect your Personal Information against loss or theft as well as unauthorized access and disclosure to protect your privacy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to the Platform, including your Personal Information. We do not accept liability for unintentional disclosure. Do not share any information on or through Circle Lab if you are concerned about the unauthorized access to such information by a third party. Your information is also stored on our service provider’s servers, and we encourage you to review their terms of service agreements and privacy policies before providing information to them. In the event there is a data breach involving unencrypted Personal Information, we, or our third party partner Sentia, will notify you via email and/or by posting a notice on the affected website.


CHILDREN'S PRIVACY:
We do not knowingly collect Personal Information from Users under the age of 13 ("Child" or "Children"). If Circle Economy, or our third party partner Unc Inc., learns that a Child's Personal Information has been collected, we will delete the account and all Personal Information associated with it. If parents or guardians believe that Circle Economy, or our third party partner Unc Inc., has unintentionally collected their Child's Personal Information, then they should contact us and request the deletion of the information at lab@circle-economy.com

Users under the age of 18 cannot enter into an agreement with Circle Economy and we ask that they do not submit any Personal Information to us. The parents or legal guardians of Users under the age of 18 must register on the Platform, agree to the TOU and enter into the agreement with Circle Economy.


ABSTAINING FROM DISCLOSING PERSONAL INFORMATION
You may, of course, decline to share Personal Information with the Platform, in which case the Platform will not be able to provide to you some of the features and functionality found on Circle Lab. For example, absent Personal Information, you cannot post an Idea or Comment.


CONTACT INFORMATION
Please direct any questions or concerns you may have about our Privacy Policy to hello@circle-lab.com, or:

Circle Economy
Attn: Circle Lab General Privacy Policy Inquiries
Mauritskade 64
Amsterdam, Netherlands 1092AD

If you feel that we do not comply with applicable privacy rules you have the right to lodge a complaint with a competent data protection authority.


COOKIES POLICY
Circle Economy is committed to protecting you and any data (anonymous or otherwise) that we collect about you online. The Platform uses cookies (and comparable technologies) to give you the best experience. The use of cookies enables Circle Economy and third parties to collect information about you and your internet behaviour and to track you. Using this information, Circle Economy and third parties can tailor content to your interests and profile. In addition, cookies enable you to share information on social media. By continuing to use the Platform, you consent to our use of cookies and other technologies. This section explains how we use cookies, why, and how this allows us to improve our service. It also provides you with information on how to manage what cookies are stored on your device.

We use data collection devices such as “cookies” on certain pages of the Platform. “Cookies” are small text files placed in a user’s computer browser to store the user’s preferences. Circle Economy stores cookies that are essential in providing the functionalities of the Platform. Circle Economy does not retain a cookie longer than necessary. We use session cookies and permanent cookies:
A session cookie can track usage such as the webpages you visit and what options you use. When you close the internet browser, the session is ended and the cookie is deleted.
A permanent cookie enables the Platform to recognize you at a subsequent visit.

Only if you have given prior consent, Circle Economy places cookies that are not strictly necessary for providing the functionalities of the Website. Through such non-strictly necessary cookies we collect information about your use of the Website and remember your preferences. Examples of collected information are which pages are visited and the length of a user session. Through these cookies we aim to improve your user experience of our Website. If you do not consent to cookies being placed, these cookies will be blocked.

If you do not wish to receive any cookies at all, you may set your browser to refuse cookies all together. Most browsers allow you to block and delete cookies. Please note that in that case you may not be able to use certain features on the Platform and you may be required to re-enter your password or Login Information more frequently. You can usually find out information about how to delete cookies on your browser through a “help” menu.

Examples of Cookies that we use:
Login cookies. These help to distinguish you from other users and enable us to provide you with a good experience. The information they use is your email address and an alphanumeric session key to help us recognise you when you return to the Site or relevant Community. It will typically last for two weeks from the time you log in if you remain logged in, or it will be deleted immediately when you log out.
Statistic tracking cookie: This is used to recognise that a user has previously visited the Platform. No identifiable personal information is contained within this cookie. It will typically last for 12 months.
Third party cookies. We use cookies from services such as Google Analytics, Google AdSense, DoubleClick, and Facebook Pixel in order to better understand traffic patterns of usage and for advertising and marketing. These typically last for up to 2 years.
Cookie consent cookie. This remembers that you have seen and dismissed the cookie notification alert, accepting the use of cookies. It will typically last for 12 months.

Only if you have given prior consent, Circle Economy will use Google Analytics' cookies. These typically last for up to 2 years. If you do not consent to the placement of such cookies, these cookies will be blocked. Google Analytics is a web analysis service that is offered by Google Inc. (Google). Google Analytics uses cookies to analyze the usage of the Website by Users. Google uses aggregated statistical data to give Circle Economy an insight in the way Users use the Website. Google may only provide these data to third parties if Google is required to do so by law, or to the extent third parties processing these data on behalf of Google. You can find more information on Google Analytics here.

Circle Economy website also provides ads with Google DoubleClick and/or AdSense services (including placed from the local domain). Google will combine the data of analytics cookies with DoubleClick and/or AdSense data. 
 
Further information on how to opt-out of cookies can be found below.

Additionally, you may encounter Cookies or other similar devices used for improving the user experience or providing added functionality on certain pages of the Platform that are placed by third parties. For example, if you view content or video submitted by another User, there may be a Cookie placed within that web page. We do not control the use of Cookies by third parties, nor do we have an obligation to do so.

We use User activity, including Users’ My Profile, on the Platform to do internal research with the potential to improve the Platform and future Challenges. We may also track the URL that you came to the Platform from (whether this URL is on the Platform or not), which URL you next go to (whether this URL is on the Platform or not), your computer browser information, your click- and surf behaviour, the length of your session, and your IP address. We do all of these things to better understand, protect and serve you and the Platform and to be able to investigate any allegations against you or us.

By using our Platform (through any device) you agree that this Cookies Policy applies to that use in addition to any other terms and conditions which may apply. By using our Platform you agree that we can place these types of Cookies on your device. Again, you can block these Cookies using your browser settings.

If you wish to restrict, opt-out, or block the Cookies which are set by any website, including this Platform, you should do this through each individual browser setting and on each device you use to access the internet. You can allow Cookies from specific websites by making them “trusted websites” in your internet browser. For more information on how to do this, and how to change your browser settings, you may wish to visit http://www.aboutads.info/choices/ and http://www.youronlinechoices.eu/

We reserve the right to make changes to our Cookies Policy. Your continued use of the Platform will constitute and confirm your agreement to and acceptance of such changes or modifications.