Privacy Policy

Privacy Policy for The Cirkle Partnership Ltd (t/a Cirkle)

 

Introduction

The Cirkle Partnership Ltd (t/a Cirkle) understands that your privacy is important to you and that you care about how your personal data is used and shared online.

This Privacy Policy describes in detail who is responsible for the personal information that we collect about you, what personal information we collect, how we will use such personal information, who we may disclose it to and your rights in relation to your personal information.

Compliance with data protection law is essential to ensure that personal data remains safe, our business operations are secure and the rights of individuals are respected.

Please read this Privacy Policy carefully and ensure that you understand it.

 

In this Privacy Policy:

Any reference to ‘we, us or our’ means The Cirkle Partnership Ltd (t/a Cirkle), a limited company registered in England (company number: 8946391), whose registered office is Canon House, 27 London End, Beaconsfield, Bucks, HP9 2HN. Our VAT registration number is 182718587

Any reference to ‘you or your’ means the person accessing and using the Website (as defined below) or existing clients and third parties

References to the Website means the website found at www.cirkle.com

Personal information is information about you and which identifies you

 

Who is responsible for the personal information that we collect?

We are the data controller for the purpose of data protection law, in respect of your personal information collected – we do not sell or pass on your information to third parties without your consent. Data stored is for internal use only. This is because we dictate the purpose for which your personal information is used and how we use your personal information.

If you have any questions regarding this Privacy Policy or the way we use your personal information, please contact our Data Protection Officer, Joanna Vowles by email or post at info@cirkle.com or by post to Cirkle, Canon House, 27 London End, Beaconsfield, Bucks, HP9 2HN

 

What personal Information do we hold about you?

The personal information we collect includes:

 

1.Information that you provide to us

Type of Personal Information Examples (not exhaustive)
Contact information Name, address, email and telephone number
Business contact information Name, address, email and telephone number
General information Gender, marital status, date of birth
Marketing preferences, marketing activities and client feedback Marketing preferences or responses to voluntary client satisfaction surveys

To improve our marketing communications, we may collect information about interaction with, and responses to, our marketing communications

 

This information may be provided:

In the course of communications between you and us (including by phone, email or otherwise)

Via our social media pages, other social media content, tools and applications

 

2.Information we collect from you

Type of information Method of data collection Examples
Technical information Through your internet browser or electronic device Certain information is collected by most websites or automatically through your electronic device, such as your IP address (i.e. your computer’s address on the internet), screen resolution, operating system type (Windows or Mac) and version, internet browser type and version, electronic device manufacturer and model, language, time of the visit and pages visited
Technical information Using cookies and online tracking Cookies are pieces of information stored directly on the device you are using to access our Website. Cookies allow us to recognise your device and to collect information such as IP address, internet browser type, time spent using the Website and the pages visited

 

3.Information we receive from other sources

Information from any of the other websites we operate or the other services we provide

Information we obtain from publicly available sources such as Facebook, LinkedIn, Twitter

Business development agencies

Information about third parties

You may provide us with personal information relating to third parties. For example, we may collect the following:Primary contact, including; Full Name, Job Title, Email and/or Phone number

We will use this personal information in accordance with this Privacy Policy. If you are providing personal information to us relating to a third party, you confirm that you have the permission of the third party to share such personal information with us and that you have made the information in this Privacy Policy available to the third party.

 

How do we use the personal information we collect about you?

Your personal information may be used by us, our employees, service providers, and disclosed to third parties for the following purposes. For each of these purposes, we have set out the legal basis on which we use your personal information.

 

Purpose Legal Basis
To carry out our obligations arising from any contracts entered into between you and us Performance of a contract between you and us
To manage complaints, feedback and queries Compliance with legal obligations to which we are subject
To carry out market research and analysis Our legitimate business interests in order for us to manage our relationship with you
To respond to an email from you Our legitimate business interests in order for us to manage our relationship with you
To carry out satisfaction surveys and analysis Our legitimate business interests in order for us to manage our relationship with you
To provide you with information about the services we offer which we believe may be of interest to you in accordance with your preferences as indicated when you entered into any agreement with us, including any marketing consent preferences Consent
To comply with any legal or regulatory obligations (including in connection with a court order) Compliance with legal obligations to which we are subject
To enforce or apply the agreements concerning you (including agreements between you and us) Performance of a contract between you and us

 

We may be required to obtain your personal information to comply with our legal requirements, to enable us to fulfil the terms of our contract with you (including Terms of Engagement and/or Scope of Work, Employment Contract etc.) or in preparation of us entering into a contract with you. If you do not provide the relevant personal information to us, we may not be able to provide a contract to you.

 

Who may we disclose your personal information to?

You agree that we may share your personal information with:

Type of Third Party Examples of Purpose Legal Basis
Our service providers Our business partners, suppliers and sub-contractors for the performance of any contract we enter into with you Performance of a contract between you and us
Our legal/professional advisers Including accountants, lawyers and other professional advisers that assist us in carrying out our business activities Our legitimate interests to seek advice to clarify our rights/obligations
Government authorities and third parties involved in court action or legal proceedings External agencies and organisations (including the police, the relevant local authority, HRMC, the UK Visas and Immigration department and other law enforcement agencies) for the purpose of complying with applicable legal and regulatory obligations Compliance with legal obligations to which we are subject

 

We may also disclose your personal information to other third parties, for example:

In the event that we sell or buy any business or assets we will disclose your personal information to the prospective seller or buyer of such business or assets

If we or substantially all of our assets are acquired by a third party (or are subject to a reorganisation within our corporate group), personal information held by us will be one of the transferred assets.

In the above examples, any personal data that you have provided will, where is relevant to any part of our business that is being transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use that data only for the same purposes for which it was originally collected by us.

 

How long will we keep your personal information?

We will not keep your personal data for longer than we need it for our legitimate purposes.

If you are an employee, we will keep your personal information for the duration of the contract of employment and a period of seven years after the contract ends.

 

Your rights

You have certain rights with respect to your personal information. The rights may only apply in certain circumstances and are subject to certain exemptions. Please see the table below for a summary of your rights. If you would like to exercise any of these rights, please email our Data Protection Officer, Joanna Vowles at info@cirkle.com.

 

Summary of your rights
Right of access to your personal information You have the right to receive a copy of your personal information that we hold about you, subject to certain exemptions.
Right to rectify your personal information You have the right to ask us to correct your personal information that we hold where it is incorrect or incomplete.
Right to erasure of your personal information You have the right to ask that your personal information be deleted in certain circumstances. For example:

(i)where your personal information is no longer necessary in relation to the purposes for which they were collected or otherwise used

(ii)if you withdraw your consent and there is no other legal ground for which we rely on for the continued use of your personal information

(iii)if you object to the use of your personal information (as set out below)

(iv)if we have used your personal information unlawfully

(v)if your personal information needs to be erased to comply with a legal obligation

 

Right to restrict the use of your personal information You have the right to suspend our use of your personal information in certain circumstances. For example:

(i)where you think your personal information is inaccurate and only for such period to enable us to verify the accuracy of your personal information

(ii)the use of your personal information is unlawful and you oppose the erasure of your personal information and request that it is suspended instead

(iii)we no longer need your personal information, but your personal information is required by you for the establishment, exercise or defence of legal claims

(iv)you have objected to the use of your personal information and we are verifying whether our grounds for the use of your personal information override your objection

Right to data portability You have the right to obtain your personal information in a structured, commonly used and machine-readable format and for it to be transferred to another organisation, where it is technically feasible. The right only applies where the use of your personal information is based on your consent or for the performance of a contract, and when the use of your personal information is carried out by automated (i.e. electronic) means
Right to object to the use of your personal information You have the right to object to the use of your personal information in certain circumstances.

For example:

(i)where you have grounds relating to your particular situation and we use your personal information for our legitimate interests (or those of a third party)

(ii)if you object to the use of your personal information for direct marketing purposes

Right to withdraw consent You have the right to withdraw your consent at any time where we rely on consent to use your personal information.
Right to complain to the relevant data protection authority You have the right to complain to the relevant data protection authority, which is, in the case of The Cirkle Partnership Ltd (t/a Cirkle), the Information Commissioner’s Office, where you think we have not used your personal information in accordance with data protection law.

 

Third party links

The Website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for how they handle your personal information. When you leave our Website, we encourage you to read the privacy notice of every website you visit.

 

Cookies

Cookies are small files saved to local storage by the user’s web browser. Cookies can be used to track, save and store information about the user’s interactions and usage of websites.Users are advised that if they wish to deny the use and saving of cookies from the Website they should take necessary steps within their web browsers security settings to block all cookies.

The Website uses cookies to improve the user experience while visiting the Website. A cookie control system is used allowing the user on their first visit to the Website to allow or disallow the use of cookies. This complies with legislation requiring explicit consent from users before storing or reading files such as cookies on a user’s computer / device.

Further information and guidance regarding cookies is available on the Information Commissioners website

https://ico.org.uk/for-the-public/online/cookies/

Other cookies may be stored to storage on your device by external vendors when this website uses referral programs, sponsored links or adverts. Such cookies are used for conversion and referral tracking. No personal information is stored, saved or collected on the website.

 

Tracking and Analytics

The Website implements tracking to allow Cirkle to understand how visitors use it. Tracking is implemented using Google Analytics which uses cookies to track visitor usage. Google will save cookies to your device in order to track and monitor your engagement and usage of the website, but will not store, save or collect.

 

Applicants

If you are contacting the HR department, we will send you a separate Privacy Notice detailed for applicants.

 

Changes to our Privacy Policy

Any changes we make to this Privacy Policy in the future will be posted on this page.The updated Privacy Policy will take effect as soon as it has been updated or otherwise communicated.

This Privacy Policy was last updated on 24th August 2018.