Privacy Policy for Cirkular Ltd

1. Information we collect
We collect information about you when you use the Cirkular platform. This information falls into 2 categories:

a. Personal information you provide to us:

• Contact, account and profile information: When you create an account, we collect your name, email address, password, address, profile image. We may also collect any other information you choose to provide to us when you communicate with us or update your profile.

• Identity information: Where appropriate, we may ask you for an image of your government-issued ID (in accordance with applicable laws) or other verification information, and/or a selfie when verifying your ID. 

• Payment information: Such as payment account or bank account information.

• Item Information: When you scan an item on the platform, we collect images of the item and detailed descriptions, including the brand, condition, specifications, and any other relevant information you provide.

• Other Information: Such as when you fill in a form, add information to your account, respond to surveys, post to community forums, participate in promotions, communicate with Cirkular Support, or share your experience with us, or provide referral information. 

b. Information we collect automatically:

• Usage Information: When you use the platform, we automatically collect information about your interactions, such as your IP address, browser type, device type, operating system, pages visited, features used, the dates and times of your activities, crash data, and read receipts. We may also collect device location information if you have enabled location services on your device.

• Cookies and Tracking Technologies: We use cookies, device identifiers, and other tracking technologies (such as web beacons and pixels) to collect information about your browsing activity, preferences, and usage patterns. This helps us personalize your experience, improve our services, and provide targeted advertising. For more information about how we use these technologies, please see our Cookie Policy [link to Cookie Policy].

• Geolocation Information: If you enable location services on your device, we collect device location information to provide location-based services, such as showing relevant items in your area and allow pricing to reflect regional market conditions.

• Payment Transaction Information. Such as payment instrument used, date and time, PayPal email address, IBAN information, your address, and other related transaction details. 

c. Sensitive Personal Information

We will never intentionally collect any special categories of personal data about you (such as racial or ethnic origin, political opinions, religious beliefs, health information, or biometric data). Please refrain from providing such information on the Platform.

d. Children's Privacy

Our Platform is not intended for use by individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected personal data from a child under 18, we will delete such data promptly.

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2. How we use your information and on what legal basis

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In some cases, we process your data based on legitimate interests. This means we process your data when it is necessary for our legitimate business interests, as long as those interests are not overridden by your fundamental rights and freedoms.

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When relying on legitimate interests, we carefully balance our interests against your data protection rights and ensure that the processing is fair, lawful, and transparent. We also take steps to minimize any potential impact on your privacy. We conduct Legitimate Interests Assessments (LIAs) to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms. These assessments help us evaluate the necessity and proportionality of the processing and implement appropriate safeguards to protect your data. 

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We collect and use your information for the following purposes and based on outlined legal grounds:

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A) To provide and improve our services

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• Essential Platform Operations: We use your data to operate the Cirkular platform and provide the services you request. This includes: 

  • Account Management: Creating and managing your account, verifying your identity, processing payments, and providing customer support. 

  • Item cataloguing and sales: Facilitating the cataloguing and sale of items, including item evaluation, offer generation, and managing transactions. 

  • Payments: Provide and improve payment services.

  • Logistics and Delivery: Arranging for the pickup, delivery, or shipping of items.

  • Communication: Enabling you to communicate with us on the platform. Sending you messages, updates, security alerts, and account notifications.

Legal Basis: Processing is necessary for the performance of a contract with you (Article 6(1)(b) GDPR).

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• Platform Improvements and Research: We use anonymized and aggregated data to improve our platform, debug, develop new features, and conduct research. This includes: 

  • AI Model Training: Not currently, but in the foreseeable future training and improving our AI models for object recognition, automated item descriptions, and pricing estimations.

Legal Basis: Consent (Article 6(1)(a) GDPR).

Your Rights: You have the right to withdraw your consent at any time. For more information, see Section 7: Your Rights Under GDPR.

Copyright Review and Data Use

• Cirkular employs automated tools and manual review processes to identify and exclude images that may contain copyrighted material. While we strive to minimize the inclusion of copyrighted elements in our AI training datasets, users are responsible for ensuring that the images they upload do not infringe on third-party rights.

• If there is any uncertainty regarding the copyright status of an image, we replace user-generated images with public domain images that are free from any copyright claims. This ensures that our AI models are trained using legally permissible content.

• We actively work with brands, designers, and artists to secure permission to use images showcasing their products. By obtaining the necessary rights, we aim to accelerate the circular economy and promote sustainable practices.

• By uploading content, users grant Cirkular a non-exclusive, royalty-free license to use their images solely for the purposes outlined in this policy, subject to compliance with applicable copyright laws.

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• Data Analysis: Analyzing usage patterns and trends to identify areas for improvement and innovation.

• Research and Development: Conducting research to enhance our services and develop new features.

Legal Basis: Legitimate Interests (Article 6(1)(f) GDPR). Our legitimate interest is to develop and improve our platform and services.

Your Rights: You have the right to object to this processing at any time. For details, refer to Section 7.

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• Safeguard the Cirkular Platform and Community: We may process your information to keep trust, accuracy and honesty high on the platform. In so doing we detect, prevent, assess, and address fraud and security risks, verify or authenticate information provided by you, including identity information, comply with our legal obligations, resolve disputes with our users, enforce our agreements with third parties, determine eligibility for certain types of cataloging and selling such as bulk selling, comply with law, respond to legal requests, prevent harm, and protect our rights, enforce our Terms and other policies, and assess or evaluate your interactions with the Cirkular Platform.

Legal Basis: Legitimate Interests (Article 6(1)(f) GDPR). Our legitimate interest is to develop and improve our platform and services.

Your Rights: You have the right to object to this processing at any time. For details, refer to Section 7.

 

• Trust and convenience maximizing pricing: We use your location and behavioral data, such as your Cirkular Score, to adjust pricing of items on our Platform. This allows us to reflect regional market conditions, user engagement levels and protect trust, accuracy and honesty on the platform, enhancing the efficiency, fairness and viability of our services. 

 

Behavioral Data: Your interactions with the Platform, including items cataloged, sales, and your Cirkular Score, which reflects your activity and reliability on the Platform.

Legal Basis: Legitimate Interests (Article 6(1)(f) GDPR). Our legitimate interest is to optimize pricing to match supply and demand, optimize item identification accuracy, improve user experience, and promote viable trading on the Platform.

Your Rights: You have the right to withdraw your consent at any time. For more information, see Section 7: Your Rights Under GDPR.

Location Data: Collected via your device's GPS or IP address or directly entered in your profile section.

Legal Basis: Consent (Article 6(1)(a) GDPR).

Your rights: You have the right to object to this processing. Details on how to exercise this right can be found in Section 7: Your Rights Under GDPR.

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User-Controlled Price Preferences: We provide a feature that allows you to voluntarily adjust the price contribution toggle in your profile settings. This enables you to indicate if you require higher or lower prices compared to the standard offers, to embrace Cirkular as the key platform for second-hand trading. You can adjust the contribution toggle at any time. This setting influences the prices you see on the Platform. By default it is set to standard. By choosing a higher contribution, you may receive lower price offers (e.g. 10% lower compared to average), thereby supporting sellers who are financially dependent on higher price offers, who can choose lower contribution settings (e.g. 10% higher offers compared to average). Goal is to develop a fully community driven pricing system that embraces community responsibility, allowing everyone to freely decide how much the Cirkular service is worth to you and how strongly you would like to subsidize the overall circular flow of used goods on the platform. 

Data Used: The preference you set is stored in your profile and used to adjust pricing accordingly.

Legal Basis: Consent (Article 6(1)(a) GDPR). By adjusting the discount toggle, you consent to the processing of this preference to influence pricing.

Your Rights: You have the right to withdraw your consent at any time. See Section 7 for more information.

We are committed to ensuring that pricing on our Platform is fair and non-discriminatory. We will never adjust prices based on personal characteristics such as age, gender, occupation, or socioeconomic status.

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B) For personalized experiences, profiling and targeted recommendations

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We use automated processing techniques, including profiling, to analyze your personal data and provide you with personalized content, recommendations, and offers that enhance your experience on our Platform. Activities Include: Clustering users into groups based on interactions, preferences, and behaviors to provide differentiated in-app experiences such as suggesting items you might be interested in selling, providing personalized offers and promotion, customizing your user interface and content based on your preferences and activity, administering referral programs, rewards, surveys, contests, or other promotional activities or events sponsored or managed by Cirkular. This helps us enhance your experience on the platform. You can opt out of targeted recommendations at any time through your account settings. However, this may limit the personalization of your experience and the relevance of suggestions.

Legal Basis: Legitimate interests (Article 6(1)(f) GDPR). Our legitimate interest is to enhance user engagement, provide relevant content, improve user satisfaction and provide personalized experiences with our services.

Your Rights: You have the right to object to this processing at any time. For details, refer to Section 7.

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C) For data monetization

 

We may use anonymized and aggregated data derived from user activity and item information for monetization purposes. This means we may:

• Generate Datasets: Create datasets that combine anonymized data from various users and items, removing any personally identifiable information.

• Analyze Market Trends: Analyze these datasets to identify trends in consumer behavior, item valuation, and market demand.

• Develop Insights: Develop insights and reports based on this analysis, which may be valuable to third parties such as retailers, manufacturers, and researchers.

• Generate Revenue: Generate revenue from the sale or licensing of these datasets or insights, contributing to the sustainability and growth of the Cirkular platform.

 

We will ensure that any data shared with third parties is fully anonymized and cannot be used to identify individual users or their specific items.

Legal Basis: Consent (Article 6(1)(a) GDPR).

Your Rights: You have the right to withdraw your consent at any time. For more information, see Section 7: Your Rights Under GDPR.

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D) For Marketing and Communication

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We may use your email address to send you promotional offers, updates, and other marketing communications, but only if you have provided your consent to receive such communications.

Legal Basis: Consent (Article 6(1)(a) GDPR).

Your Rights: You have the right to withdraw your consent at any time. For more information, see Section 7: Your Rights Under GDPR.

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E) For Legal and Compliance purposes

We may use your data for legal and compliance purposes, such as:

• Complying with applicable laws and regulations.

Legal Basis: Compliance with a legal obligation (Article 6(1)(c) GDPR). 

• Protecting against fraud, illegal activities, and breaches of our Terms and Conditions.

Legal Basis: Legitimate interests (Article 6(1)(f) GDPR). Our legitimate interest is to protect our rights and the safety of our users.

Your Rights: You have the right to object to this processing at any time. For more information, see Section 7: Your Rights Under GDPR.

• Responding to legal requests and court orders.

Legal Basis: Compliance with a legal obligation (Article 6(1)(c) GDPR). 

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By allowing Cirkular to use your anonymized data, you directly contribute to overall success of the Cirkular platform via:

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• Improved object recognition: leading to faster and more accurate item identification, meaning less work for you and more effective operations for us.

• More precise pricing models: resulting in more accurate and competitive offers for everyone, crucial  for viability of the platform.

• Acceleration of circular economy: enabling Cirkular to accelerate the circular economy by creating additional revenue streams we will use to support and accelerate second-hand trade on the platform e.g. offering more competitive prices for your items (even those with low or negative resale value).

• Enhanced platform features: such as personalized household recommendations such as complementary second-hand products and a more streamlined selling (and in the future buying) experience, by connecting you to relevant second-hand partners.

 

3. Data Storage and Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. Here are the specific retention periods for different categories of data:

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Account Information: We retain your account information (such as your name, email address, and other information provided by you to us) for as long as your account is active. Upon account deletion, we will delete this information, except for any data we are legally required to retain (e.g., for tax or accounting purposes). This data will be retained for a maximum of 10 years after account deletion. Such data will be retained securely and access will be restricted.

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Item Information: We retain item information (including images and descriptions) for as long as your account is active or as long as the item remains cataloged on the platform. If you delete an item or your account, we will delete the associated item information, except for any data needed for legal or operational purposes (e.g., transaction history). 

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Transaction History: We retain transaction history (including purchase and sale records). E.g. typically for 7 years for financial records to comply with legal and tax obligations. 

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Customer Support Interactions: We retain records of your interactions with our customer support team for as long as necessary to resolve your inquiries and improve our services. This data is typically retained for a maximum of 2 years. 

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AI Model Training Data: We may retain anonymized images and data indefinitely to train and improve our AI models. This data does not contain any personally identifiable information and is used to analyze market trends and develop insights. Doing so we adhere to the outlined Copyright Review and Data Use practices in section 2.

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Anonymized Data for Monetization: We may retain anonymized and aggregated datasets created for data monetization purposes indefinitely. This data does not contain any personally identifiable information and is used to analyze market trends and develop insights. Doing so we adhere to the outlined Copyright Review and Data Use practices in section 2.

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Anonymized Data for Targeted Recommendations: We retain anonymized data used for targeted recommendations for as long as necessary to provide personalized suggestions and offers. You can opt-out of targeted recommendations at any time, which will result in the deletion of this data.

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Cookie Data: We retain data collected through cookies and similar tracking technologies in accordance with our Cookie Policy [link to Cookie Policy]. This data is typically retained for a period ranging from a few days to several months, depending on the type of cookie.

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We regularly review our data retention periods to ensure we are not retaining data longer than necessary.

We take appropriate technical and organizational measures to protect your data during storage and retention. For more information about our data security practices, please see Section 4.

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4. Data Security

While no organization can guarantee perfect security, we are continuously implementing and updating administrative, technical, organizational and physical security measures to help protect your information against unlawful or unauthorized access, use, disclosure, loss, destruction, or alteration. These measures include:

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Encryption: We use encryption techniques to protect your data both in transit and at rest. This includes encrypting sensitive information like passwords and payment details during transmission and storing data on secure servers with restricted access. 

Access Controls: We implement access controls to limit access to your personal data to authorized personnel only. This includes role-based access control, multi-factor authentication, and regular security training for our employees. 

Secure Storage: We store your data on secure servers with appropriate physical and technical security measures in place, such as firewalls, intrusion detection systems, and regular security audits. 

Data Minimization: We collect and process only the minimum amount of personal data necessary for the purposes outlined in this Privacy Policy. 

Regular Security Assessments: We conduct regular security assessments and vulnerability scans to identify and address potential security risks. 

Third-Party Security: We carefully select and monitor third-party service providers who handle your data to ensure they maintain adequate security standards.

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We conduct Data Protection Impact Assessments (DPIAs) for processing activities that may pose a high risk to your rights and freedoms, ensuring that we have identified and mitigated potential risks.

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Data Breach Procedures

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In the event of a data breach, we will:

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• Investigate: Promptly investigate the breach to determine the scope and impact.

• Contain: Take immediate steps to contain the breach and prevent further unauthorized access.

• Notify: Without undue delay and, where feasible, within 72 hours of becoming aware of the breach, we will notify the relevant supervisory authority. If the breach is likely to result in a high risk to the rights and freedoms of individuals, we will also inform those individuals without undue delay.

• Report: Provide the supervisory authority and affected individuals with information about the nature of the breach, the types of data involved, the likely consequences, and the measures taken to address the breach.

• Remediate: Implement measures to remediate the breach and prevent similar incidents in the future.

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You also have a role to play in protecting your data by keeping your account credentials secure and following good security practices.

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​5. Sharing Your Information

We may share your personal data in the following circumstances:

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a. With Service Providers

We share your information with trusted third-party service providers who assist us in providing and improving our services. These providers are carefully selected and contractually obligated to protect your data and use it only as instructed by Cirkular.

Legal Basis: Processing is necessary for the performance of a contract (Article 6(1)(b) GDPR) and/or our legitimate interests (Article 6(1)(f) GDPR).

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Categories of service providers we may share data with include:

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• Payment Processors: To process payments for item sales.

• Cloud Storage Providers: To securely store and manage our data, including user information and item information.

• Analytics Companies: To analyze platform usage data and improve our services.

• AI Model Partners:  We are sharing limited data with AI model providers such as Anthropic and OpenAI. Although, we have opted out under certain scenarios they may still look at selected data e.g safety concerns. Here you can find their terms: Anthropic Terms, OpenAI Terms. 

• Logistics Partners: To handle the pickup, delivery, and shipping of items. This may include sharing your name, address, and contact information with the logistics provider to facilitate the delivery process.

• IT Service Providers: To provide technical support, maintenance, and security for our platform.

• Customer Support Providers: To assist us in responding to user inquiries and providing customer support.

• Marketing and Communication Platforms: To send you marketing communications, if you have provided your consent.

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b. With Re-commerce Partners

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With your explicit consent, we may share your information with re-commerce partners to provide you with additional services. This allows us to provide you with a wider range of options for selling or buying items.

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Short-term: To help you find the best buyers for your items and to facilitate efficient transactions, our re-commerce partners may access our item database to view details about specific items, such as their descriptions, images, and estimated values. This data will not include any information that could directly identify you as the seller. Long-term: In the future, we may provide ads from these partners on our platform or share anonymized and aggregated data about your preferences with them to enable them to show you more relevant ads on other platforms. If you click on an ad and express interest in a partner's services, we may share your contact information and relevant item details with that partner to facilitate a potential transaction. This will allow you to easily set up an account with the partner or purchase items directly from our platform. We will always obtain your consent before sharing any personal data with re-commerce partners for these purposes. These partners may also receive anonymized item data, such as aggregated information about popular products or trends. This data does not include any personally identifiable information.

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Legal Basis: Consent (Article 6(1)(a) GDPR).

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c. With Investment Partners

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We may share your information with investment partners, such as retail investment firms or neo-brokers, to enable you to reinvest the proceeds from your item sales e.g. to set-up an account on their platform if you choose to use their services. This may include sharing your name, contact information, and investment preferences with these partners if you choose to use their services.

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Legal Basis: Consent (Article 6(1)(a) GDPR).

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d. With Non-Profit Organizations

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We may share anonymized and aggregated trend data with non-profit organizations or social organizations. This data may include insights into popular product categories, donation patterns, or overall platform trends. We do not share any personally identifiable information with these organizations.

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e. For Legal Reasons

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We may disclose your information if required to do so by law or in good faith belief that such action is necessary to:

  

• Comply with a legal obligation, such as a court order, subpoena, or warrant.   

• Protect and defend the rights or property of Cirkular, our users, or others.

• Prevent or investigate possible wrongdoing in connection with the platform.

• Protect the personal safety of users of the platform or the public.  

Legal Basis: Compliance with a legal obligation (Article 6(1)(c) GDPR).

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f. Business Transfers

In the event of a merger, acquisition, or sale of all or a portion of our assets, your data may be transferred to the acquiring entity. We will notify you via email and/or a prominent notice on our website of any such change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.  

 

Data Transfers and Security

When we share your data with third parties, we take steps to ensure its protection:

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• Contractual Obligations: We enter into data processing agreements with our service providers that require them to implement appropriate technical and organizational security measures and to process your data only as instructed by Cirkular.

• Data Security Measures: We require our service providers to maintain adequate security standards to protect your data against unauthorized access, use, or disclosure.

• Limited Data Sharing: We share only the minimum amount of data necessary for the specific purpose.

• Data Transfers Outside the EEA: If we transfer your data outside the European Economic Area (EEA), we will ensure that appropriate safeguards are in place, such as Standard Contractual Clauses, to protect your data.

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Notification: Where appropriate and/or legally required, we may notify users about legal requests, unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon or harm to Cirkular, our users, or expose Cirkular to a claim of obstruction of justice.

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​6. Cross-Border Data Transfers

Your personal data may be transferred to and stored in countries outside the European Economic Area (EEA) for the following reasons:

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• Server Location: Our primary servers are currently located within the EEA. However, we may use service providers located outside the EEA, which may involve transferring your data to those countries.

• Data Sharing with Partners: We may share your data with partners located outside the EEA, such as in the United States, as described in Section 5.

• Future Expansion: As we expand our services globally, we may transfer your anonymized data to countries outside the EEA to provide and improve our services in those regions.

• Other Transfers: We may transfer your data outside the EEA for other legitimate business purposes, such as research collaborations or data analysis.

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When transferring your data outside the EEA, we will ensure that appropriate safeguards are in place to protect your data and comply with GDPR requirements. These safeguards may include:

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• Standard Contractual Clauses: We will enter into Standard Contractual Clauses approved by the European Commission with our service providers and partners located outside the EEA. 

• Adequacy Decisions: We will rely on adequacy decisions adopted by the European Commission for countries that have been deemed to provide an adequate level of data protection. 

• Binding Corporate Rules: Where applicable, we adhere to internal policies approved by data protection authorities.

• Other Appropriate Safeguards: We may implement other appropriate safeguards as required by applicable data protection laws.

You can request a copy of the appropriate safeguards by contacting us at [email protected].

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7. Your Rights Under GDPR

As a data subject under the GDPR, you have the following rights regarding your personal data:

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• Right of Access: You have the right to request access to your personal data that we hold. This includes the right to obtain confirmation that your data is being processed, the purposes of the processing, the categories of data involved, and the recipients of your data.   

• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you.   

• Right to Erasure ('Right to be Forgotten'): You have the right to request the deletion of your personal data under certain circumstances, such as when your data is no longer necessary for the purposes for which it was collected, you withdraw your consent, or you object to the processing. However, this right is not absolute and may be limited by legal obligations or other legitimate interests. E.g. We may retain your personal information as necessary for our legitimate business interests, such as prevention of money laundering, fraud detection and prevention, and enhancing safety. For example, if we suspend a Cirkular Account for fraud or safety reasons, we may retain information from that Cirkular Account to prevent that Member from opening a new Cirkular Account in the future.

• Right to Restriction of Processing: You have the right to request restriction of processing of your personal data in certain situations, such as when you contest the accuracy of your data, the processing is unlawful, or you object to the processing based on legitimate interests.

• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller without hindrance from us, where technically feasible.   

• Right to Lodge a Complaint: If you believe that we have not complied with our obligations under the GDPR, you have the right to lodge a complaint with a supervisory authority. In Germany, the supervisory authority for data protection is the Bundesbeauftragter für Datenschutz und Informationsfreiheit – "BfDI”.

• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw consent at any time through your account settings in the app or by contacting us at [email protected] without affecting the lawfulness of processing based on consent before its withdrawal.

• Right to Object: You have the right to object to the processing of your personal data based on legitimate interests. To exercise this right, please contact us at [email protected] or adjust your preferences in your account settings. If you object, we will cease processing your data for these purposes unless we have compelling legitimate grounds that override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims

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Exercising Your Rights

To exercise any of these rights, please contact us at [email protected]. We will respond to your request without undue delay and at the latest within one month of receipt. If your request is complex or you submit multiple requests, we may extend the response time by a maximum of two further months. If this is necessary, we will inform you within one month of receiving your request and explain the reasons for the delay.

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​​8. Use of Cookies and Tracking Technologies

We use cookies and similar tracking technologies (such as web beacons, pixels, and local storage) to enhance your experience on our platform, analyze usage patterns, and provide personalized content and advertisements. For non-essential cookies, we require your consent.

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What are Cookies?

Cookies are small text files that are placed on your device when you visit a website. They are widely used to make websites work more efficiently and to provide information to the website owners.   

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How We Use Cookies

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We use cookies for various purposes, including:

• Essential Cookies: These cookies are necessary for the platform to function properly and provide basic features, such as secure login, selling cart functionality, and fraud prevention.   

• Performance and Analytics Cookies: These cookies help us analyze how users interact with our platform, allowing us to improve its performance, identify potential issues, and enhance user experience. For example, we use these cookies to track page views, button clicks, and error messages.

• Functionality Cookies: These cookies enable us to remember your preferences and provide enhanced features, such as personalized recommendations and language settings.

• Targeting and Advertising Cookies: These cookies are used to deliver personalized advertisements and track the effectiveness of our marketing campaigns. They may be set by us or by third-party advertising partners.

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Cookie Control and Consent

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When you first visit our Platform, we will present you with a cookie consent banner. You can choose to accept or reject non-essential cookies. Your preferences can be updated at any time through our Cookie Settings.

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You can also manage your cookie preferences and disable non-essential cookies through your browser settings. Most web browsers allow you to control cookies through their settings, such as accepting or rejecting all cookies, or accepting only certain types of cookies. 

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However, please note that disabling certain cookies may affect the functionality of our platform.

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Our Cookie Policy

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For more detailed information about the specific cookies we use, their purposes, and how to manage your preferences, please see our Cookie Policy [link to Cookie Policy].

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9. Third Party Links

Our Platform may contain links to external websites or services. Please note that we are not responsible for the privacy practices of such third parties. We encourage you to review their privacy policies before providing any personal data.

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​10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, new features, legal requirements, or for other operational, legal, or regulatory reasons.  If we do so, we will post the revised Privacy Policy and update the “Last Updated” date at the top. In case of material changes, we will also provide you with notice of the modification by email at least thirty (30) days before the effective date.

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Material Changes

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Material changes are those that significantly affect your rights or obligations, such as:

• Changes to the types of personal data we collect.

• Changes to how we use your personal data.

• Changes to how we share your personal data.

• Changes to your data subject rights.

• Changes to our data security practices.

• Changes to our cross-border data transfer practices.

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If we make material changes that affect how we process your personal data or require new consent, we will inform you in advance and request your consent where necessary.

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We encourage you to review this Privacy Policy periodically to stay informed about our data practices. If you disagree with the revised Privacy Policy, you can cancel your Account. If you do not cancel your Account before the date the revised Privacy Policy becomes effective, your continued access to or use of the Cirkular Platform will be subject to the revised Privacy Policy. By continuing to use our platform after we post any modifications to the Privacy Policy, you agree to those changes.   

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​11. Contact Us
If you have any questions about this Privacy Policy or our data practices, please contact us at:

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Cirkular World Ltd

71-75 Shelton Street Covent Garden 

WC2H9JQ 

London

Email: [email protected]

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12. Definitions

Undefined terms in this Privacy Policy have the same definition as in our Terms of Service (“Terms”).