Privacy Policy

September 2021

Introduction

1.1      We are committed to respecting and protecting your privacy. This Privacy Policy sets out the type of information we collect from you and what we do with that information.

Please read this Privacy Policy carefully as by visiting our website (https://circa5000.com), using our mobile Application(s) (App) or opening a CIRCA5000 account, you will be bound by the terms of this Privacy Policy.

1.2     We will ask you to consent to our use of cookies in accordance with the terms of this policy when you first visit our website.

1.3     Our website incorporates privacy controls which affect how we will process your personal data.

By using the privacy controls, you can specify whether you would like to receive direct marketing communications and limit the publication of your information. You can access the privacy controls via account settings within the App.

1.4     If you have signed up to a CIRCA5000 account this Privacy Policy should be read together with our

Customer Terms & Conditions.

1.5     In this policy, “we”, “us” and “our” refer to CIRCA5000.

About us

2.1     For the purpose of this Privacy Policy and the Data Protection Act 1998, CIRCA5000 Ltd of 3rd Floor, 86 – 90 Paul Street, London EC2A 4NE is the ‘data controller’.

Information we may collect from you

3.1     During the course of opening a CIRCA5000 account, the information you give to us may include your name, address, email address, phone number, date of birth, National Insurance number, bank account and other financial details, copies of personal identification documents (such as your passport or driving licence) and photographs or other descriptions of your likeness. You may also provide   us   with   certain   information   by   filling   in   other   forms,   entering   competitions   or promotions or by corresponding with us by phone, email, or text message.

3.2     When you visit our website or use our App we may collect or receive your IP address, URL, browser   information,   plug-in   types,   operating   system   and   platform   as   well   as   your   login information. We work closely with third parties (for example: business partners, technical, payment and delivery service providers, advertising networks, tracking and analytics providers (including Google), search information providers, lead generation agencies and credit reference agencies) and may receive information about you from them, such as your clickstream through our website and App, the products you viewed and the page interactions.

3.3     We, or our third party providers, may also use cookies to collect information about you. This helps us to provide you with a good experience while you use our website and our App. See our Cookie Policy for more details.

What we use your information for

4.1     We use the information we collect about you to:

(i)      Verify your identity and to conduct anti-money laundering checks;

(ii)     provide you with the products and services you have requested;

(iii)     carry out our contractual obligations in relation to contracts entered into with you or with our business partners and service providers;

(iv)     notify you about changes to our products or services;

(v)     ensure that content from our website and our App is presented in the most effective manner for you and for your devices;

(vi)     administer our website and App and for internal operations such as troubleshooting, data analysis, testing and research purposes;

(vii)     help maintain the safety and security of our website and App;

(viii)     make suggestions to you (and other customers) about our products or services and to send such information via email, SMS message, targeted social media and our in-App secure notification centre; and

(ix)     measure or understand the effectiveness of advertising we send to you (and other customers) and to deliver relevant advertising to you

Processing of data

5.1     We will access, use, and share the Information as required to fulfil our contractual obligations to you or subsequent requests for support by you.

5.2     We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.

5.3     We may use third-party analytics services (such as Google Analytics) to evaluate your use of the Platform, compile reports on activity, analyse performance metrics, and collect and evaluate other information relating to the Platform and mobile and Internet usage. These third parties use cookies and other technologies to help analyse and provide us the data. You consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy.  For more information on these third parties, including how to opt out from certain data collection, please visit the site/s below. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Platform.

(I)   Google Analytics, please visit https://www.google.com/analytics

5.4     We may process your account data (“account data”). The account data may include your name and email address. The account data may be processed for the purposes of providing our services,   ensuring   the   security   of   our   website   and   services,   maintaining   back-ups   of   our databases and communicating with you. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

5.5     We may process your personal data that are provided in the course of the use of our services (“service data”). The service data may be processed for the purposes of providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.

5.6     We may process information that you provide to us for the purpose of subscribing to our email communications (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters. The legal basis for this processing is consent.

5.7     We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata   associated   with   the   communication.   Our   website   will   generate   the   metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.

5.8     We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

5.9     We may process any of your personal data identified in this policy where necessary for the purposes   of   obtaining   or   maintaining   insurance   coverage,   managing   risks,   or   obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.

5.10   In addition to the specific purposes for which we may process your personal data set out in this

Section 5, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Disclosing your personal data

6.1     Advertisers and advertising networks that require the information to select and serve relevant adverts to you and others. We do not disclose information about identifiable individuals to our advertisers, but we may provide them with anonymised or aggregate information about our users.

6.2     Analytics and search engine providers that assist us in the improvement and optimisation of our site (for example Google for the purpose of its Google Analytics service).

6.3     If we sell or buy any business or assets, in which case we may need to disclose your personal information to the prospective seller or buyer of such business or assets.

Or if we, or substantially all of our assets, are acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets.

6.4     if we are under a duty to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or Apply our Website & App Terms of Use, our Customer Terms & Conditions and other agreements; or to protect our rights, property, or safety or those of our customers or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.

Security of your information

7.1     Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your information transmitted to our website or App. Transmission is at your own risk.

7.2     Where we have given you, or where you have chosen, a password or personal identification number (PIN) which enables you to access certain parts of our App, you are responsible for keeping this password or PIN confidential. We ask you not to share this password or PIN with anyone.

7.3     The hosting facilities for our website are situated in the UK.

Or if we, or substantially all of our assets, are acquired by a third party, in which case personal information held by it about its customers will be one of the transferred assets.

7.4     You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

retaining and deleting personal data

8.1     Personal data that we process for any purpose shall not be kept for longer than is necessary for that purpose.

8.2     We may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

8.3     To request erasure of your personal data please contact us at hi@circa5000.com.

changes to this privacy policy

9.1     We may make changes to this Privacy Policy by publishing a new version on our website, so please review it every now and then to ensure you are happy with any changes.

9.2     If appropriate we will notify you by email about changes. Remember, you will be bound by this policy.