Privacy Policy

1. Introduction

Welcome to Circular Global Ledgers S.A.! At Circular, we value your privacy and are committed to protecting your personal information. We treat your personal data confidentiality and according to the prevailing legal data protection regulations and this privacy policy (this "Privacy Policy"). This Privacy Policy outlines how we collect, use, store, and protect the data we obtain from users of our blockchain website. We understand the importance of transparency and want to ensure that you have a clear understanding of how your information is handled when you interact with our services. By accessing and using our website, you acknowledge that you have read and understood this Privacy Policy. If you have any questions or concerns regarding our privacy practices, please contact us using the information provided at the end of this policy.

We must emphasize that transmitting data over the internet (e.g., through email communication) cannot guarantee complete security and may contain vulnerabilities. It is not possible to fully protect personal information from unauthorized access by third parties.

By providing us with your personal data, you acknowledge and agree to the collection, usage, and disclosure of such information as outlined in this Privacy Policy. If you provide the personal data of another individual, it implies that you have informed them of the purposes for which we require their personal data, and they have given consent to the collection, usage, and disclosure of their personal data in accordance with this policy.

2. Information Collected

At Circular, we collect certain personal information from users of our blockchain website. The types of information we collect may include but are not limited to:

•  Personal identification details, such as your name and contact information (e.g., email address).
•  Technical information related to your interaction with our website, such as your IP address, device information, and browsing behavior.
•  Information voluntarily provided by you, such as when you register an account, submit a contact form, or participate in interactive features of our website.
•  Blockchain transaction data associated with your use of our services.

Please note that we adhere to the principles of privacy by design and aim to minimize the collection of unnecessary personal information. We only collect data that is relevant and necessary to provide our services and improve the user experience.

3. Use of Information

At Circular, we use the information collected to provide and enhance our blockchain website services. The primary purposes for which we may use your information include:

•  Providing access to our website and its features, functionalities, and personalized content;
•  Responding to your inquiries, requests, or customer support needs;
•  Analyzing user behavior and preferences to improve our website's performance and user experience;
•  Sending you important notifications, updates, and promotional communications related to our services, subject to your consent where required by applicable laws;
•  Preventing fraudulent or unauthorized activities and ensuring the security of our website;
•  Complying with legal obligations, enforcing our terms of service, and protecting our rights and the rights of other users; and
•  Please note that we will only use your information in accordance with applicable laws and for the purposes stated in this Privacy Policy. We do not sell or rent your personal information to third parties without your explicit consent.

4. Data Retention

We will retain your personal information for as long as you maintain an active account with us or as needed to provide you with our services. If you request the deletion of your account or withdraw your consent to process your personal information, we will take steps to delete or anonymize your data in a manner consistent with our data retention policies and applicable laws.

Please note that even after your account is deleted or your information is anonymized, we may retain and use certain data as necessary to comply with legal obligations, resolve disputes, enforce our agreements, and protect our rights.

We regularly review our data retention practices to ensure that we do not retain personal information longer than necessary.

5. Data Sharing

At Circular, we understand the importance of maintaining the privacy of your personal information. We do not sell, trade, or rent your personal data to third parties for their marketing purposes. However, we may share your personal information in the following circumstances:

•  With service providers and business partners: we may engage trusted third-party service providers and business partners who assist us in operating our website and providing our services. These entities are bound by confidentiality obligations and are only permitted to use your personal information for the purposes specified by Circular;
• For legal and compliance purposes: we may disclose your personal information if required by law, regulation, legal process, or governmental request. This includes responding to subpoenas, court orders, or similar legal processes, as well as establishing or exercising our legal rights or defending against legal claims;
•  In the event of a business transfer: If Circular undergoes a merger, acquisition, reorganization, or sale of all or a portion of its assets, your personal information may be transferred as part of the transaction. We will ensure that the receiving party agrees to protect your personal information in a manner consistent with this Privacy Policy;
•  With your consent: We may share your personal information with third parties if you provide us with explicit consent to do so; and
•  Please note that when we share your personal information with third parties, we take reasonable steps to ensure that they maintain the confidentiality and security of your information. We require them to only use your personal information in accordance with our instructions and applicable privacy laws.

6. Security Measures

Circular takes the security of your personal information seriously and implements appropriate technical and organizational measures to protect it from unauthorized access, loss, misuse, alteration, or disclosure. We maintain reasonable safeguards to ensure the confidentiality, integrity, and availability of your data. Our security measures include, but are not limited to:

• Encryption: we employ encryption techniques to protect sensitive information during transmission and storage.
• Access controls: we restrict access to personal information to authorized personnel and entities who require access for legitimate business purposes.
• Regular assessments: we conduct regular security assessments and audits to identify and address potential vulnerabilities.
• Data minimization: we collect and retain only the personal information that is necessary for the purposes stated in this Privacy Policy.
• Employee training: our employees undergo training to ensure they understand the importance of data privacy and security.

However, it is important to note that no method of transmission or storage over the internet is completely secure. While we strive to protect your personal information, we cannot guarantee its absolute security. We encourage you to take appropriate measures to protect your personal information, such as keeping your login credentials confidential and using secure networks when accessing our website.

7. Right of access to and correction of personal data

You have the right to be informed about your personal data in our possession or under our control, their origin and addressee and the purpose of data processing as well as the right to correction of those data at any time. For further questions and questions concerning personal data, feel free to contact us under the address published in the imprint/legal notice or send an email to: info@circularlabs.io

8. Privacy Policy for the European Union (EU)

Circular is dedicated to upholding the highest level of integrity in our dealings with customers, investors, and other business partners. When you use Circular’ s services and electronic media, we may collect, process, and/or disclose data that can identify you or make you identifiable ("Personal Data") in accordance with this Privacy Policy. We may obtain your Personal Data directly from you when you send us emails or through other interactions with us, or indirectly from third parties who legally provide your Personal Data to us.

8.1 Consent for International Data Transfers to Countries with Lower Levels of Data Protection

If you do not wish for your Personal Data to be transferred to third countries outside the EU/EEA, please refrain from providing your consent and do not send any Personal Data to Circular.

Please note that Circular collects your Personal Data directly from the country where you are based and may store it on servers located outside the EU/EEA, which may be operated by third-party service providers. In order to ensure secure and sufficient data storage systems, Circular needs to engage these third-party service providers due to their legitimate interests. Circular carefully selects these service providers, ensuring that they comply with applicable privacy laws, prioritize personal data protection, and implement state-of-the-art technical and organizational measures. Consequently, your potential interests in not transferring your personal data do not outweigh the legitimate interests of Circular.

BY CONSENTING TO THIS PRIVACY POLICY, YOU ALSO CONSENT TO THE INTERNATIONAL TRANSFER AND PROCESSING OF YOUR PERSONAL DATA BY THESE THIRD PARTIES IN THIRD COUNTRIES OUTSIDE THE EU/EEA. PLEASE REFER TO OUR WEBSITE FOR A LIST OF THE THIRD-PARTY SERVICE PROVIDERS AND THE RESPECTIVE THIRD COUNTRIES INVOLVED IN THE PROCESSING OF YOUR PERSONAL DATA.

8.2 WITHDRAWAL OF CONSENT

If you provide consent, you have the right to withdraw it at any time. Withdrawing consent does not affect the lawfulness of processing based on consent prior to its withdrawal. Upon withdrawal, we will cease processing your Personal Data, including storage. This provision only applies to entirely voluntary processing, not to processing that is necessary or obligatory in any way. To withdraw your consent, please contact us via email at: info@circularlabs.io

8.3 GDPR

When involving third-party processors in the performance of our services and contractual obligations, which may require sharing personal data, we have entered into data processing agreements with them in accordance with Article 28 of the European General Data Protection Regulation (GDPR) as amended. Additionally, where necessary, we have implemented further appropriate safeguards as specified in Articles 46-49 of the GDPR. To request a list of third-party processors to which we disclose your personal data, please contact us at info@circularlabs.io

One specific processor Circular Labs works with is Stripe, Inc. ("Stripe"). Stripe processes personal data on our behalf for purposes such as customer identification, accreditation, and contributions. For more information, please refer to Stripe's Terms of Service and Privacy Policy at Stripe.

8.4 Consent and Withdrawal

Any consent you provide is voluntary, and you have the right to withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. Once you withdraw your consent, we will cease processing your Personal Data, including its storage. Please note that this provision applies only to processing that is entirely voluntary and does not apply to processing that is necessary or obligatory.

To withdraw your consent, please contact us via email at info@circularlabs.io

9. Cookies and Tracking Technologies

Circular Labs uses cookies and similar tracking technologies to enhance your experience on our blockchain website. Cookies are small text files that are placed on your device when you visit our website. They allow us to collect certain information, such as your preferences, browsing patterns, and website interactions.

We use cookies for various purposes, including but not limited to:

•  Providing personalized content and recommendations based on your interests;
•  Analyzing website traffic and user behavior to improve our services and website functionality;
•  Enabling certain features and functionalities of our website;
•  Understanding and optimizing our marketing efforts; and
•  You can control or disable cookies through your browser settings. Please note that disabling cookies may limit your access to certain features and functionalities of our website.

We may also utilize other tracking technologies, such as web beacons and pixel tags, to gather information about your website usage and engagement. These technologies help us analyze trends, track user movements, and gather demographic information.

Third-party analytics and advertising services may also place cookies and utilize tracking technologies on our website. These cookies are subject to the privacy policies of the respective third parties, and Circular Labs has no control over their practices.

By continuing to use our website, you consent to the use of cookies and tracking technologies as described in this Privacy Policy.

10. User Rights

At Circular, we recognize and respect your rights regarding your personal information. Depending on the applicable laws of your jurisdiction, you may have the following rights:

•  Right to access: You have the right to request access to the personal information we hold about you and receive a copy of that information.
•  Right to rectification: If you believe that the personal information we hold about you is inaccurate or incomplete, you have the right to request that we correct or update it.
•  Right to erasure: You may request the deletion of your personal information in certain circumstances, such as when it is no longer necessary for the purposes for which it was collected, or when you withdraw your consent and there is no other legal basis for processing.
•  Right to restrict processing: You have the right to request the restriction of the processing of your personal information in certain situations, such as when you contest the accuracy of the data or when the processing is unlawful.
•  Right to data portability: If applicable, you may have the right to receive a copy of your personal information in a structured, commonly used, and machine-readable format, and to transmit that data to another controller.
•  Right to object: You have the right to object to the processing of your personal information in certain circumstances, such as when the processing is based on legitimate interests or for direct marketing purposes.
•  Right to withdraw consent: If we rely on your consent as the legal basis for processing your personal information, you have the right to withdraw that consent at any time.

To exercise any of these rights, or if you have any questions or concerns regarding the processing of your personal information, please contact us using the information provided at the end of this policy. We will respond to your request in accordance with applicable data protection laws and regulations. You have the right to lodge a complaint with the competent data protection authority. The competent data protection authority in Switzerland is the Federal Data Protection and Information Commissioner. Competent data protection authorities of EU countries can be accessed through this link. https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm

11. Legal Basis and Consent

Circular relies on various legal bases for processing your personal information. The legal basis may include the necessity of processing for the performance of a contract, compliance with a legal obligation, protection of vital interests, consent, or legitimate interests pursued by Circular or a third party.

Where we rely on your consent to process your personal information, we will obtain that consent in accordance with applicable laws and regulations. You have the right to withdraw your consent at any time by contacting us using the information provided at the end of this policy. Please note that the withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

By using our website and providing your personal information, you consent to the collection, use, and processing of your information as described in this Privacy Policy. If you do not agree with any aspect of this policy, please do not use our website or provide your personal information.

12. Children's Privacy

Protecting the privacy of children is important to us. Our website is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children without the consent of their parents or guardian. If we become aware that we have inadvertently collected personal information from a child without appropriate consent, we will take steps to delete that information as soon as possible.

If you are a parent or guardian and believe that your child has provided personal information to us without your consent, please contact us immediately using the information provided at the end of this policy. We will promptly take necessary actions to address the situation.

We encourage parents and guardians to supervise and actively participate in their children's online activities to ensure a safe and child-friendly online environment.

Customize this paragraph by specifying the applicable age requirement and adapting the language to comply with the relevant children's privacy laws and regulations in your jurisdiction.

13. Contact Information

At Circular, we may periodically update this Privacy Policy to reflect changes in our practices, services, or legal requirements. We reserve the right to modify or amend this policy at any time. When we make updates, we will revise the 'Last Updated' date at the top of this policy.

We encourage you to review this Privacy Policy periodically to stay informed about how we collect, use, and protect your personal information. If we make significant changes that affect your rights or alter the way we handle your personal information, we will provide notice through our website or other communication channels.

By continuing to use our website after any modifications to this Privacy Policy, you acknowledge and agree to the updated terms.

14. Changes to the Privacy Policy

If you have any questions, concerns, or inquiries regarding this Privacy Policy or our privacy practices, please contact us using the following information:

Circular Global Ledgers S.A.

Address: Via Maggio 1, 6900 Lugano (Switzerland)
Email: info@circularlabs.io

If you have a direct business relationship with Circular, Circular is your Data Controller according to Art. 4 para. 7 GDPR. For any requests you can contact us as follows:

Our data privacy officer is Edward J. Gildea and you can contact us at info@circularlabs.io

We may process your data on behalf of a contract partner of yours (e.g. internet-shop, vendor, seller, service provider). In this case, the privacy policy of your partner applies. Please contact your contract partner for more information.

We will make reasonable efforts to respond to your request or inquiry promptly and address any concerns you may have regarding the privacy and security of your personal information.

15. Additional Legal Disclosures

In addition to the information provided in this Privacy Policy, there may be specific legal disclosures required by applicable laws, regulations, or industry standards. Circular Global Ledgers S.A. is committed to complying with all such legal obligations.

Please be aware that this Privacy Policy does not cover the practices of third parties, including any third-party websites or services linked to or from our website. We encourage you to review the privacy policies of those third parties to understand how they collect, use, and disclose your information.

Furthermore, nothing in this Privacy Policy is intended to create or establish any rights enforceable by any party, except as otherwise required by applicable laws or agreed upon in separate written agreements.

It is important to note that this Privacy Policy applies solely to the information collected by Circular Global Ledgers S.A. through our website and services, and it does not govern the privacy practices of other entities that we do not control or own.