Legal
Data Privacy
Circular Communications OOD
Privacy Policy
Circular Communications OOD understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits circular-communications.com (“Our Website”).
We will only collect and use personal data in ways that are described in this Privacy Policy (“Policy”) and in ways that are consistent with your and our rights and obligations under the law.
Please read this Policy carefully and ensure that you understand it.
1. Definitions and Interpretation
1.1. In this Policy, Account means an account required to access and/or use certain areas and features of Our Website the following terms shall have the following meanings:
2. Information About Us
2.1 Our Website is owned and operated by Circular Communications OOD, a limited company registered in Bulgaria and registered address at Bulgaria, Sofia, Sredets region, Evlogi and Hristo Georgievi N: 111, floor 1.
2.2 You can contact us at contactus@circular-communications.com.
3. What Does This Policy Cover?
3.1 This Policy applies only to your use of Our Website. Our Website may contain links to other websites. Please note that we have no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.
4. What Is Personal Data?
4.1 Personal data is defined by the Data Protection Act 2018 and the (Retained EU Legislation) Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (the “UK GDPR”) (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
4.2 Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
5.1 Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:
a) The right to be informed about our collection and use of your personal data. This Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Clause 15.
b) The right to access the personal data we hold about you. Clause 13 will tell you how to do this.
c) The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Clause 15 to find out more.
d) The right to be forgotten, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold. Please contact us using the details in Clause 15 to find out more.
e) The right to restrict (i.e. prevent) the processing of your personal data.
f) The right to object to us using your personal data for a particular purpose or purposes.
g) The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
h) The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
5.2 For more information about our use of your personal data or exercising your rights as outlined above, please contact us using the details provided in Clause 15.
5.3 It is important that your personal data is kept accurate and up-to-date. If any of the personal data we hold about you changes, please keep us informed as long as we have that data.
5.4 Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
5.5 If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact us first, using the details in Clause 15.
6. What Data Do You Collect and How?
6.1 Depending upon your use of Our Website, we may collect and hold some or all of the personal and non-personal data described below:
- name
- email address
- phone number
- location – only viaa active user input
6.2 . We do not collect any ‘special category’ or ‘sensitive’ personal data, personal data relating to children and/or data relating to criminal convictions and/or offences.
7. How Do You Use My Personal Data?
7.1 Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:
7.2 With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email, telephone, text message and/or post with information, news, and offers on products and service we and/or our partners’ may provide. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and any other applicable laws and regulations on electronic communications that apply to us from time to time. You will always have the opportunity to opt-out.
7.3 We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.
7.4 Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.
We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Clause 15.
7.5 If we need to use your personal data for a purpose that is unrelated to, or incompatible with, the purposes for which it was originally collected, we will inform you and explain the legal basis which allows us to do so.
7.6 In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.
8. How Long Will You Keep My Personal Data?
8.1 We will not keep your personal data for any longer than is necessary in light of the reasons for which it was first collected. Your personal data will therefore be kept for 6 months on our servers.
9. How and Where Do You Store or Transfer My Personal Data?
9.1 We will only store or transfer your personal data in Europe. This means that it will be fully protected under the Data Protection Legislation.
10. Do You Share My Personal Data?
10.1 We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions:
· To the extent required to provide Our Website to you;
· If we sell, transfer, or merge parts of our business or assets, in which case any new owner of our business may continue to use your personal data in the same ways that we have used it, as specified in this Policy.
· In some limited circumstances, where we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.
10.2 If any of your personal data is shared with a third party, as described above, we will take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Clause 9.
10.3 If any personal data is transferred outside of the United Kingdom or EEA, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation.
11 How Can I Control My Personal Data?
11.1 In addition to your rights under the Data Protection Legislation, set out in Clause 5, when you submit personal data via Our Website, you may be given options to restrict our use of your personal data. In particular, we aim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails and at the point of providing your details and by managing your Account).
11.2 You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.
12. Can I Withhold Information?
12.1 You may access certain areas of Our Website without providing any personal data at all. However, to use all features and functions available on Our Website you may be required to submit or allow for the collection of certain data.
13. How Can I Access My Personal Data?
13.1 If you want to know what personal data we have about you, you can ask us for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.
13.2 All subject access requests should be made in writing and sent to the email or postal addresses shown in Clause 15.
13.3 There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.
13.4 We will respond to your subject access request within 20 days and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.
14 How Do You Use Cookies?
14.1 We do not use cookies of any kind.
15 How Do You Contact Us?
15.1 To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details:
Email address: contactus@circular-communications.com
16 Changes to this Privacy Policy
16.1 We may change this Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.
16.2 Any changes will be immediately posted on Our Website and you will be deemed to have accepted the terms of the Policy on your first use of Our Website following the alterations. We recommend that you check this page regularly to keep up-to-date. This Policy was last updated on 25.06.2022