Privacy Policy

This Privacy Policy applies to all information collected by CIRCL Pte. Ltd. and/or its related entities, affiliates and subsidiaries (individually and collectively, “CIRCL“) under Clause 1 below.
For the purpose of this Policy, “we” and “our” shall refer to CIRCL.

 

1.

When is information collected from you?

1.1

When you register for or use any of our services on websites or install mobile applications owned and/or operated by us.

1.2

When you take part in any contest, survey or promotion conducted by us and/or our business partners.

1.3

When you register as a member of websites owned and/or operated by us, or hosted by us on behalf of our business partners or use services on such websites or mobile applications.

 

 

2.

What information is collected from you

2.1

When you create a CIRCL account, or otherwise provide us with your personal information through the Site and/or the CIRCL Apps, the personal information we collect may include your:

Name

Email Address

Mobile number

Address

Date of birth

Gender

Food and beverage preferences and/or restrictions

2.2

You must only submit to us, our authorised agent, the Site, or the CIRCL Apps, information which is accurate and not misleading and you must keep it up to date and inform us of changes (more information below). We reserve the right to request for documentation to verify the information provided by you.

We will only be able to collect your personal information if you voluntarily submit the information to us. If you choose not to submit your personal information to us or subsequently withdraw your consent to our use of your personal information, we may not be able to provide you with our Services. You may access and update your personal information submitted to us at any time as described below.

If you provide personal information of any third party to us, we assume that you have obtained the required consent from the relevant third party to share and transfer his/her personal information to us.

If you sign up for CIRCL using your social media account or link your CIRCL account to your social media account or use certain other CIRCL social media features, we may access information about you which you have voluntarily provided under your social media provider in accordance with the provider’s policies and we will manage your personal data which we have collected in accordance with CIRCL’s privacy policy.

   

3.

What is the information used for?

3.1

Information which you provide to us may be used and disclosed by us and our affiliates, business partners and contractors (who may be based outside Singapore) for the following purposes:

 

3.1.1

to respond to your requests and queries;

3.1.2

to provide goods and services to you;

3.1.3

to verify and process your personal particulars and payments;

3.1.4

to communicate with you;

3.1.5

to enforce contractual and legal rights and obligations;

3.1.6

for marketing research, fraud management, user profile and statistical analysis;

3.1.7

to send you information, promotions, updates, and marketing and advertising materials in relation to our goods and services and those of third party organisations;

3.1.8

to compare information, and verify with third parties in order to ensure that the information is accurate; and

3.1.9

for any other purposes for which we have obtained your consent, including during the registration process under our Member Terms and Conditions.

3.2

Further, we will use the information you provide to administer your account (if any) with us; verify and carry out financial transactions in relation to payments you make online; audit the downloading of data from the Platform; improve the layout and/or content of the pages of the Platform and customise them for users; identify visitors on the Platform; carry out research on our users’ demographics and behaviour; provide you with information we think you may find useful or which you have requested from us, including information about our or third party sellers’ products and services, provided you have indicated that you have not objected to being contacted for these purposes;

3.3

In exceptional circumstances CIRCL may be required to disclose personal information, such as when there are grounds to believe that the disclosure is necessary to prevent a threat to life or health, or for law enforcement purposes, or for fulfillment of legal and regulatory requirements and requests.

3.4

In the event that you participate in contests or other promotional programs on our websites sponsored or organized by third parties or purchase goods and services offered by third parties or offer goods and services to third parties on our sites and/or the CIRCL Apps, your information may be disclosed to and used by such third parties.

 

 

4.

Use of cookies

4.1

CIRCL uses “cookies”, where a small data file is sent to your browser to store and track information about you when you enter our websites.  The cookie is used to track information such as the number of users and their frequency of use, profiles of users and their preferred sites and/or mobile applications. 

4.2

Like many web site and mobile applications operators, CIRCL may use an independent company (the “Third Party Market Research Company”) to measure and analyse usage across CIRCL web sites and mobile applications.  CIRCL uses the Third Party Market Research Company’s services to collect the following core information on the usage of our web sites and/or mobile applications, including:

 

4.2.1

The number of page views (or page impressions) that occur on CIRCL web sites and mobile applications;

4.2.2

The number of unique visitors to CIRCL web sites and mobile applications;

4.2.3

How long these unique visitors (on average) spend on CIRCL web sites and mobile applications when they do visit; and

4.2.4

Common entry and exit points into CIRCL web sites and mobile applications.

4.3

This information is collated by the Third Party Market Research Company and provided to CIRCL to assist in analysing the usage of CIRCL web sites and mobile applications. Such data is also accessible by media organizations and research companies, for the purpose of conducting industry comparisons with other Internet and mobile application services.

4.4

Pages on CIRCL web sites may be coded with software which enables the Third Party Market Research Company and CIRCL to track visitors to our web sites.

   

5.

Withdrawal of Consent

5.1

You may communicate your objection to our continual use and/or disclosure of your personal information for any of the purposes and in the manner as stated above at any time by contacting us at our e-mail address:  support@circl.it.

5.2

Please note that if you communicate your objection to our use and/or disclosure of your personal information for the purposes and in the manner as stated above, depending on the nature of your objection, we may not be in a position to continue to provide our products or services to you or perform on any contract we have with you. Our legal rights and remedies are expressly reserved in such event.

   

6.

Updating Your Personal Information

6.1

You can update your personal information anytime by accessing your account on the CIRCL App. 

6.2

We take steps to share the updates to your personal information with third parties and our affiliates with whom we have shared your personal information if your personal information is still necessary for the above stated purposes.

   

7.

Accessing Your Personal Information

7.1

If you would like to view the personal information we have on you or inquire about the ways in which your personal information has been or may have been used or disclosed by CIRCL within the past year, please contact us at our e-mail address below. We reserve the right to charge a reasonable administrative fee for retrieving your personal information records.

7.2

If you have an account with CIRCL, you may access details of your order by logging into your account on the App. Here you can view the details of your orders that have been completed, those which are open and administer your details. You undertake to treat your CIRCL login credentials and order details confidentially and not make it available to unauthorised third parties. We cannot assume any liability for misuse of your CIRCL login credentials or order details, except as stated in the Terms of Service.

   

8.

Security of Your Personal Information

8.1

CIRCL ensures that all information collected will be safely and securely stored. We protect your personal information by:

-Restricting access to personal information

-Maintaining technology products to prevent unauthorised computer access

-Securely destroying your personal information when it is no longer needed for any legal or business purpose

8.2

If you believe that your privacy has been breached by CIRCL, please contact us at our e-mail address:  support@circl.it.

Your login credentials are the keys to your account. Please do not share your CIRCL login credentials with anyone. If you do share your credentials with others, you will be responsible for all actions taken in the name of your account and the consequences. If you lose control of your credentials, you may lose substantial control over your personal information and other information submitted to CIRCL. You could also be subject to legally binding actions taken on your behalf. Therefore, if your login credentials have been compromised for any reason or if you have grounds to believe that your login credentials have been compromised, you should immediately contact us and change your password. You are reminded to log off of your account and close the browser when finished using a shared computer.

   

9.

Minors

9.1

CIRCL does not sell products for purchase by children. If you are under 18 years old, you may use our website only with the involvement of a parent or guardian.

   

10.

Collection of Computer Data

10.1

CIRCL or our authorized service providers may use cookies, web beacons, and other similar technologies for storing information to help provide you with a better, faster, safer and personalized experience when you use the Services and/or access the Site.

10.2

When you visit CIRCL, our company servers will automatically record information that your browser sends whenever you visit a website. This data may include:

Your computer’s IP address
Browser type
Webpage you were visiting before you came to our Site
The pages within the Site or mobile applications which you visit
The time spent on those pages, items and information searched for on the Site or mobile applications, access times and dates, and other statistics.

This information is collected for analysis and evaluation in order to help us improve our website and the services and products we provide.

10.3

Web beacons are small graphic images that may be included on our Service and the Site. They allow us to count users who have viewed these pages so that we can better understand your preference and interests.

   

11.

Changes to Privacy Policy

11.1

CIRCL shall regularly review the sufficiency of this Privacy Policy. We reserve the right to modify and change the Privacy Policy at any time. Any changes to this policy will be published on the Site.

   

12.

CIRCL’s Right

12.1

YOU ACKNOWLEDGE AND AGREE THAT CIRCL HAS THE RIGHT TO DISCLOSE YOUR PERSONAL INFORMATION TO ANY LEGAL, REGULATORY, GOVERNMENTAL, TAX, LAW ENFORCEMENT OR OTHER AUTHORITIES OR THE RELEVANT RIGHT OWNERS, IF CIRCL HAS REASONABLE GROUNDS TO BELIEVE THAT DISCLOSURE OF YOUR PERSONAL INFORMATION IS NECESSARY FOR THE PURPOSE OF MEETING ANY OBLIGATIONS, REQUIREMENTS OR ARRANGEMENTS, WHETHER VOLUNTARY OR MANDATORY, AS A RESULT OF COOPERATING WITH AN ORDER, AN INVESTIGATION AND/OR A REQUEST OF ANY NATURE BY SUCH PARTIES. TO THE EXTENT PERMISSIBLE BY APPLICABLE LAW, YOU AGREE NOT TO TAKE ANY ACTION AND/OR WAIVE YOUR RIGHTS TO TAKE ANY ACTION AGAINST CIRCL FOR THE DISCLOSURE OF YOUR PERSONAL INFORMATION IN THESE CIRCUMSTANCES.

   

13.

Contacting CIRCL

13.1

If you wish to withdraw your consent to our use of your personal information, request access and/or correction of your personal information, have any queries, comments or concerns, or require any help on technical or cookie-related matters, please feel free to contact us (and our Data Protection Officer) at support@circl.it.

(Last updated on 28 November 2017)

 

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