Version 1.1 May 2018
This privacy statement discloses the privacy practices of Open Circle Center, Inc. and all websites owned or operated by or on behalf of Open Circle Center, Inc., including, without limitation, opencirclecenter.org (collectively referred to as “our websites”).
Legal Entity: Open Circle Center Inc
Email Address: firstname.lastname@example.org
Postal Address: PO Box 11201, Berkeley, CA 94712
It is important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at email@example.com
What Information We Collect
The types of information that we collect fall under two general categories: Personally identifiable information (PII) and non-personally identifiable information (non-PII). PII consists of any information which can be used to specifically identify you as an individual and may include.
- Identity Data may include your first name, maiden name, last name, username, marital status, title, date of birth and gender.
- Contact Data may include your billing address, delivery address, email address and telephone numbers.
- Financial Data may include your bank account and payment card details.
- Transaction Data may include details about payments between us and other details of purchases made by you.
- Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.
- Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.
- Usage Data may include information about how you use our website, products and services.
- Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.
Non-PII consists of aggregate information or any information that does not reveal your identity. The following sections describe how your PII and non-PII are collected by us, and how we use such information.
We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offences.
How We Collect and Use Information
- Log Files. Any time you visit any of our websites, our servers automatically gather information from your browser (such as your IP addresses, browser type, Internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks) to analyze trends, administer the site, prevent fraud, track visitor movement in the aggregate, and gather broad demographic information. For example, we may log your IP address for system administration purposes. IP addresses are logged to track a user’s session. This gives us an idea of which parts of the site users are visiting. We do not share the log files externally.
- Web Beacons. “Web beacons” (also known as “clear gifs” and “pixel tags”) are small transparent graphic images that are often used in conjunction with cookies in order to further personalize our website for our users and to collect a limited set of information about our visitors. We may also use web beacons in email communications in order to understand the behavior of our customers. We do not link the web beacons to any PII.
- Information About You. When you register, enroll or place an order for any products or services, we collect information about you. For interactive content and community services where you may choose to have a public profile, we may display your non-PII information to other community members and visitors. You may choose to provide us with your photo(s) or video(s) and by providing us such content, you agree that we may make them available to other members and visitors. Except as otherwise stated in this privacy statement, we do not disclose your PII to you or other users of our services.
- Purchase Information. To process purchases, we may require your name, address, phone number, email address and credit card information. Such information is used primarily to process your order or as otherwise described herein. Credit card transactions are processed using industry standard Secure Socket Layer (SSL) and/or strong encryption (3DES) by a third party, which only uses your information for that purpose.
- Emails. We may require an email address from you when you register for our services. We use your email address for both transactional (e.g., order confirmation and renewal processing) and promotional (e.g., newsletters, new product offerings, special discounts, event notifications, special third-party offers) purposes. Email messages we send you may contain code that enables our database to track your usage of the emails, including whether the email was opened and what links (if any) were clicked. If you would rather not receive promotional emails from us, please see the section below labeled “Choice/Opt-Out.” We reserve the right to send you certain communications relating to our services, such as service announcements and administrative messages, without offering you the opportunity to opt out of receiving them.
- Demographic Data. Demographic data is also collected at our site. We may use this data to tailor our visitors’ experience at our site, showing them content that we think they might be interested in, and displaying the content according to their preferences. Some of this information may be shared with advertisers on a non-personally identifiable basis.
- Online Survey Data. We may periodically conduct voluntary member surveys. We encourage our members to participate in such surveys because they provide us with important information regarding the improvement of our services. You may also volunteer for certain surveys that we may offer to our users, and any additional rules regarding the conduct of such surveys will be disclosed to you prior to your participation. We do not link the survey responses to any PII, and all responses are anonymous.
- Public Forums. We may make discussion boards available to our users and visitors. Any information that is disclosed in these areas becomes public information and you should exercise caution when deciding to disclose any PII. Please consult the community guidelines for each discussion board for other specific information.
Purposes for processing your personal data
Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we process such data. We have also explained what our legitimate interests are where relevant.
We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at firstname.lastname@example.org if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Purpose/Activity Type of data Lawful basis for processing To register you as a new customer (a) Identity
Performance of a contract with you To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests to recover debts owed to us
To manage our relationship with you which will include:
(b) Asking you to provide feedback, leave a review or take a survey
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests to keep our records updated and to study how customers use our products/services
To enable you to partake in a prize draw, competition or complete a survey (a) Identity
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests to study how customers use our products/services, to develop them and grow our business
To administer and protect our business and website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) (a) Identity
(a) Necessary for our legitimate interests for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise
(b) Necessary to comply with a legal obligation
To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising (a) Identity
(e) Marketing and Communications
Necessary for our legitimate interests to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy To use data analytics to improve our website, products/services, marketing, customer relationships and experiences (a) Technical
Necessary for our legitimate interests to define types of customers for our products and services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy To make suggestions and recommendations to you about goods or services that may be of interest to you (a) Identity
Necessary for our legitimate interests to develop our products/services and grow our business
You will receive marketing communications from us if you have:
(i) requested information from us or purchased goods or services from us; or
(ii) if you provided us with your details and ticked the box at the point of entry (if applicable for your region) of your details for us to send you marketing communications; and
(iii) in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent or by emailing us at email@example.com.
Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may process your personal data without your knowledge or consent where this is required or permitted by law.
Disclosure of Your Information to Third Parties
- Disclosure By Law. You acknowledge and agree that we may disclose information you provide if required to do so by law, at the request of a third party, or if we, in our sole discretion, believe that disclosure is reasonable to comply with the law, requests or orders from law enforcement or any legal process, protect or defend our rights or property, or protect someone’s health or safety.
- Disclosure to Trusted Third Parties By Us. We may share your non-PII with third parties, but not in a manner that would reveal your identity. We may share your PII, sometimes in conjunction with your non-PII with service providers that may be associated with us to perform functions on our behalf. For example, outsourced customer care agents or technology assistants may need access to your information to perform services for you. Your information will be treated as private and confidential by such service providers and not used for any other purpose than we authorize. In addition, from time to time, we may share PII (such as email or mailing address) about our user base with carefully selected third parties, so they can offer goods and services that we believe may be of interest to our users. If you do not wish to receive offers from our trusted partners, you can change your email preferences at any time by following the steps outlined in the “Choice/Opt-Out” section below.
We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.
We may partner with third-party advertising agencies or other service providers to serve ads on our website on behalf of Open Circle Center or third-party advertisers (e.g., retailers of goods or services). These companies may employ cookies and web beacons to measure advertising effectiveness. Any information that these third parties collect via cookies and web beacons is completely anonymous. Some of these third-party advertising agencies may be members of the Network Advertising Initiative, which offers you the option to opt out of ad targeting from its member agencies by following the procedures listed here.
We will only share your information with third parties in the ways defined in this privacy statement.
Our age restrictions for different services are set forth in each website’s applicable Terms and Conditions of Service. We do not target any of our sites or services to children under the age of 13, and in compliance with the Children’s Online Privacy Protection Act, any information we may receive from users we believe to be under the age of 13 will be purged from our database.
We have security measures in place to protect against the loss, misuse and alteration of information stored in our databases. These measures include use of Secure Socket Layer (SSL) and/or strong encryption (3DES) technology during credit card transactions and administrator sessions, as well as other security measures which are applied to all data at rest and in transit. We will exercise reasonable care in providing for the secure transmission of information between your computer and our servers, but we cannot ensure or warrant the security of any information transmitted to us over the Internet and accept no liability for any unintentional disclosure.
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for seven years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
YOUR LEGAL RIGHTS
Under certain circumstances, you have rights under data protection laws to include but not limited to privacy laws in the United States and General Data Protection Regulation in the European Union in relation to your personal data. These include the right to:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer of your personal data.
- Right to withdraw consent.
If you wish to exercise any of the rights set out above, please email us at firstname.lastname@example.org.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Links to Other Sites
We are not responsible for the privacy practices or the content of other websites that may be linked to this site or of any third party advertisers.
Click on the “unsubscribe” link on the bottom of the e-mail.
You may opt out of the DoubleClick cookie by visiting the Google advertising opt-out page.
Or you may opt out of Google Analytics by visiting the Google Analytics Opt-out page.
In order to stop displaying our ads on your Facebook account, please manage your Facebook settings by clicking here: Facebook Settings
Updating Your Information
Open Circle Center provides users the following options for changing and modifying information previously submitted.
- For any services where you have an account page, you may change your credit card (if applicable), e-mail address, password and other information from the account settings or preferences page; or
- You can send mail or electronic mail to the address listed above, providing us with your account information and letting us know which information you wish to update.
Contacting the Website
If you have any questions about this privacy statement, the practices of this site, or your dealings with any of our websites, you can contact: email@example.com.
Acceptance of Privacy Statement
Your use of our websites, including any dispute concerning privacy, is subject to this privacy statement and the applicable Terms and Conditions of Service. BY USING OUR WEBSITES, YOU ARE ACCEPTING THE PRACTICES SET OUT IN THIS PRIVACY STATEMENT AND THE APPLICABLE TERMS AND CONDITIONS OF SERVICE.
Your continued use of any portion of our website following posting of the updated privacy statement will constitute your acceptance of the changes.