UPDATED JANUARY 2020
We may collect and receive information about users of our Services ("users," "you," or "your") from various sources, including: (i) information you provide through your user account on the Services (your "Account"); (ii) your use of the Services, including placing an order; and (iii) from third-party websites, services, and partners.
1. INFORMATION WE COLLECTA) Information You Provide
B) Information We Collect When You Use Our Services
(i) Cookies and Other Tracking Technologies. As is true of most websites, we gather certain information automatically and store it in log files. In addition, when you use our Services, we may collect certain information automatically from your device. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, clickstream data, landing page, and referring URL. To collect this information, a cookie may be set on your computer or device when you visit our Services. Cookies contain a small amount of information that allows our web servers to recognize you. We store information that we collect through cookies, log files, and/or clear gifs to record your preferences. In some countries, including countries in the European Economic Area ("EEA"), the information referenced above in this paragraph may be considered personal information under applicable data protection laws.
C) Information We Receive from Third Parties:
(i) Third-Party Partners. We may receive publicly available information about you from our third-party partners and combine it with data that we have about you.
2. HOW WE USE INFORMATION
We use the information we collect in various ways, including to:
- Provide, operate, and maintain our Services;
- Improve, personalise, and expand our Services;
- Understand and analyse how you use our Services;
- Develop new products, services, features, and functionality;
- Communicate with you, including for customer service, to provide you with updates and other information relating to the Service, and for marketing and promotional purposes;
- Process your transactions;
- For compliance purposes, including enforcing our Terms of Service, or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.
3. HOW WE SHARE INFORMATION
Full Circle does not sell individuals’ information. We will share it only with our authorised Data Processors, who must always act on our instructions as the Data Controller under relevant data protection laws including GDPR.
4. LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION
Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.
However, we will normally collect personal information from you only (i) where we need the personal information to perform a contract with you; (ii) where the processing is in our legitimate interests and not overridden by your rights; or (iii) where we have your consent to do so. We have a legitimate interest in operating our Services and communicating with you as necessary to provide these Services, for example when responding to your queries, processing an order, improving our platform, undertaking marketing, or for the purposes of detecting or preventing illegal activities.
In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person.
If we ask you to provide personal information to comply with a legal requirement or 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 (as well as of the possible consequences if you do not provide your personal information).
5. THIRD-PARTY SERVICES
We may use suppliers who also set cookies on our website on our behalf to deliver the services that they are providing.
For example, Google Analytics collect anonymised data- more information can be found at: http://www.google.co.uk/intl/en/analytics/privacyoverview.html and: http://code.google.com/apis/analytics/docs/concepts/gaConceptsCookies.html
Full Circle is committed to protecting your information. To do so, we employ a variety of security technologies and measures designed to protect information from unauthorized access, use, or disclosure. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. However, please bear in mind that the Internet cannot be guaranteed to be 100% secure.
7. DATA RETENTION
We retain personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements).
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
If you are a registered user, you may access certain information associated with your Account by logging into our Services.
To protect your privacy and security, we may also take reasonable steps to verify your identity before updating or removing your information. The information you provide us may be archived or stored periodically by us according to backup processes conducted in the ordinary course of business for disaster recovery purposes. Your ability to access and correct your information may be temporarily limited where access and correction could: inhibit our ability to comply with a legal obligation; inhibit our ability to investigate, make or defend legal claims; result in disclosure of personal information about a third party; or result in breach of a contract or disclosure of trade secrets or other proprietary business information belonging to Full Circle or a third party.
9. YOUR DATA PROTECTION RIGHTS UNDER THE GENERAL DATA PROTECTION REGULATION (GDPR)
If you are a resident of the EEA, you have the following data protection rights:
- If you wish to access, correct, update, or request deletionof your personal information, you can do so at any time by emailing firstname.lastname@example.org
- In addition, you can object to the processingof your personal information, ask us to restrict the processing of your personal information, or request portability of your personal information. Again, you can exercise these rights by emailing email@example.com
- You have the right to opt-out of marketing communicationswe send you at any time. You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing emails we send you. To opt-out of other forms of marketing, please contact us by emailing firstname.lastname@example.org
- Similarly, if we have collected and processed your personal information with your consent, then you can withdraw your consentat any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authorityabout our collection and use of your personal information. For more information, please contact your local data protection authority.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
10. YOUR CHOICES
You can use some of the features of the Services without registering for an account, thereby limiting the type of information that we collect, and limiting you from placing an order.
You may unsubscribe from receiving certain promotional emails from us. If you wish to do so, simply follow the instructions found at the end of the email. Even if you unsubscribe, we may still contact you for informational, transactional, account-related, or similar purposes.
11. CHILDREN'S PRIVACY
13. INTERNATIONAL DATA TRANSFERS