Cookie Policy​

Privacy

At Circlewise we are committed to protecting your privacy. This Cookie Policy applies to your use of our Website and our Platform. This Cookie Policy governs our data collection, processing and usage practises and is in compliance with all applicable national data protection regulations.

When visiting our Website

When using our Platform

Registration in our Platform

In order to obtain access to our Platform you need to register. If you register to our platform and/or enter into a contractual relationship with us, we record all data, including personal data, which has been provided by you such as your name, address, telephone number or email address. We solely record personal data that is voluntarily provided by you.

We may also collect information about how you interact with our Platform, such as date and time, information about your browser, operating system and computer or device, pages viewed and items clicked.

Cookies in our Platform

We use cookies in our Platform to improve and optimise the usability for our clients. You can find general information about cookies in “Cookies” above. The cookies we use in our Platform are listed below:

Domain Cookie name Description of the cookie
manager.circlewise.io PHPSESSID
user
These cookies are set when you sign in to our Platform and are used to keep you logged in. It stores a unique ID for your session and expires when you close your browser.
.circlewise.io Intercom-lou-xin6hwai
intercom-session-xin6hwai
Cookie from Intercom to allow you to chat with our support team. See “Platform support with Intercom” below.

Platform support with Intercom

Our Platform uses third-party analytics services to help understand your usage of our services. In particular, we provide a limited amount of your information (such as sign-up date and some personal information like your email address) to Intercom, Inc. (“Intercom”) and utilize Intercom to collect data for analytics purposes when you use our Platform. You can find more information about Intercom in “Website support with Intercom”.​

Product related emails

We send out emails notifying you about critical Platform updates, such as maintenance notifications or new billing documents. You can opt-out of those emails at any time.

The emails are sent by means of “Campaign Monitor”, an email marketing platform of the Australian company Campaign Monitor Pty Ltd. The email addresses of our active platform users, as well as other data described in the context of this information, are being stored on the servers of Campaign Monitor. Campaign Monitor uses this information to send out and evaluate the newsletters on our behalf. In addition, Campaign Monitor can use this data to optimize or improve its own services, e.g. for the technical optimization of the dispatch and the presentation of the newsletter or for economic purposes in order to determine from which countries the recipients come from. However, Campaign Monitor does not use the data of our newsletter recipients to contact them independently or transfer data to third parties.

For more information on the privacy practices of Campaign monitor, please visit https://www.campaignmonitor.com/policies/#privacy-policy. Campaign Monitor’s services are governed by its terms of use which can be found at https://www.campaignmonitor.com/policies/#terms-of-use. If you would like to opt out of having this information collected by or submitted to Campaign Monitor, please contact us.

How we use the information we collect

Compliance with Our Cookie Policy

We use the information we collect only in compliance with this Privacy Policy. Clients who register to our Platform are obligated through our agreements with them to comply with this Privacy Policy.

We Never Sell Personal Information

We will never sell your Personal Information to any third party.

Use of Personal Information

In addition to the uses identified elsewhere in this Cookie Policy, we may use your Personal Information to:

  • To provide, maintain and improve the Offerings and our other products and services, including to operate certain features and functionality of the Platform (for example, by remembering your information so that you will not have to re-enter it during this or subsequent visits);
  • To process your inquiries and otherwise deliver customer service;
  • To control unauthorized use or abuse of the Platform and our other products and services, or otherwise detect, investigate or prevent activities that may violate our policies or be illegal;
  • To analyze trends, administer or optimize the Platform, monitor usage or traffic patterns (including to track users’ movements around the Platform) and gather demographic information about our user base as a whole;
  • To communicate directly with you, including by sending you newsletters, promotions and special offers or information about new products and services. Your opt-out options for promotional communications are described in “Your Controls and Choices”.

Legal basis for processing Personal Information (EEA visitors only)

If you are a visitor/customer located in the European Economic Area (“EEA”), Target Circle AS is the data processor of your personal information. As we offer our Platform as a Software-as-a-Service to advertisers, we only processes personal data on behalf of the advertiser who acts as data controller or if we need the personal information to perform a contract with you. If we ask you to provide personal information to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not. Target Circle has designated as Data Protection Officer (DPO), as required by Article 37 of the GDPR. Target Circle’s DPO can be contacted at privacy@targetcircle.com. Target Circle is under the supervision of the Norwegian Data Protection Authority (Datatilsynet) as required by article 51 of the GDPR and in addition to that audited annually by its mandated auditors: Myrdahl og Sveen Støperiveien 26 2010 Strømmen Norway

How we share information we collect

We do not sell, trade, share or transfer your personal information to third parties except in the following limited circumstances:

  • We may share your personal information with our parent companies, subsidiaries and affiliates;
  • We may share your personal information with third-party service providers to permit such parties to provide services that help us with our business activities, which may include assisting us with marketing, advertising our product/service offerings, or providing, maintaining and improving the features and functionality of the Platform, among other things. For example, we may provide personal information to our service providers for direct emailing of our newsletters or notifications of our product/service offerings;
  • We may share your personal information with third parties (including our service providers and government entities) to detect, prevent, or otherwise address fraud or security or technical issues;
  • We may share your personal information with our business partners who offer a service to you jointly with us, for example our publishers;
  • We may share and/or transfer your personal information if we become involved in a merger, acquisition, bankruptcy, or any form of sale of some or all of our assets;
  • We may share your personal information with a third party if we have your consent to do so.

How to access & control your personal data

When you use the Platform, we make good faith efforts to provide you with access to your personal information upon your request and either provide you the means to correct this information if it is inaccurate or to delete such information at your request if it is not otherwise required to be retained by law or for legitimate business purposes. You may access, review, correct, update, change or delete your information at any time. To do so sign in to your account, go to your settings, and make the desired changes, or if you don’t have access to the Platform please contact us at help@targetcircle.com with your name and the information requested to be accessed, corrected or removed.

We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort (for instance, requests concerning information residing on backup tapes), jeopardize the privacy of others, would be extremely impractical, or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.

Tracking opt-outs

Our tracking service saves cookies in the browser of users that use websites of our clients and saves an identifier based on other information received from that browser. The cookies and identifiers are solely used to accurately track the success of our clients’ advertising campaigns and to attribute this success to the right publisher. We do not save, process or use any other personal data when doing so.

We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort (for instance, requests concerning information residing on backup tapes), jeopardize the privacy of others, would be extremely impractical, or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.

Deactivating cookies

If you don’t want the cookies to be saved in your browser you can set this up in your browser settings. Depending on your browser you can completely deactivate cookie storage, deactivate it only for specific websites or let it notify you when a cookie is set. It should be noted however that cookies play an important role in the usability of the internet; deactivating them might worsen your browsing experience. Alternatively, you can also delete cookies from your browser at any time. We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort (for instance, requests concerning information residing on backup tapes), jeopardize the privacy of others, would be extremely impractical, or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.

Communication preferences

If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the instructions included on such communications. Please note, however, that you may be unable to opt-out of certain service-related communications.We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort (for instance, requests concerning information residing on backup tapes), jeopardize the privacy of others, would be extremely impractical, or for which access is not otherwise required. In any case where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.

Changes to the cookie policy

We reserve the right to change our Cookie Policy at any time. If we make changes, we will post them and will indicate on this page the policy’s new effective date. If we make material changes to this policy, we will notify you by email or through notice on the Platform.

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