Last Reviewed: May 18, 2021, Updated: June 3, 2021, Posted: August 25, 2021
1400 Broadfield Boulevard, Suite 625
Houston, TX 77084
This policy applies to information we collect:
• From your use and/or view of this website www.circulus.com and related Circulus webpages (the “Site”).
• In email, text and other electronic messages and communications between you and the Site, as well as transactions between you and Circulus through the Site.
It does not apply to information collected by:
• Us offline or through any other means, including on any other website operated by any third party (including our affiliates and subsidiaries); or
• Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Site.
Information We Collect, Storage, and Retain
As you use the Site, Circulus may ask you for certain information, including but not limited to your name, company name, email address, postal address, and telephone number. If you provide such information, we collect and store it. You provide such information voluntarily. In general, you can visit the Site without telling us who you are or revealing any personal information about yourself; however, you must provide personal information in order to contact us, subscribe to Circulus email alerts, or apply for a job.
When you apply for a job through the Site, we also may ask you for additional information, such information may include, without limitation, your name, mailing addresses, zip code, phone number, email address, education and work background, and resume. This information will only be used to evaluate and potentially contact you about current or future positions at Circulus.
We retain the personal information you provided indefinitely, subject to your request to have such information and data deleted from our systems as detailed below.
Additionally, Circulus may use automatic data collection technologies such as cookies and other tracking technologies (described more fully below) to collect non-personally identifiable information when you visit the Site, including but not limited to the type of browser and operating system that you are using, your IP address, aggregate data about the number of visits to the Site, and aggregate data about the pages visited, but in doing so we do not connect this information with your personal information such as your name or email address to personally identify you. For more information, please see the following section.
Cookies and Online Tracking Technologies
Circulus does not collect user personally identifiable information over time and across third-party websites, and we do not permit third parties to gather information passively on the Site for behavioral advertising purposes.
Additionally, some Internet browsers have a ‘do not track’ feature that lets you tell websites that you do not want to have your online activities tracked. These features are not yet uniform, so we are currently not set up to respond to such signals.
How We Use the Information We Collect
We use information that we collect about you or that you provide to us, including any personal information:
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To provide you with notices about your transactions or communications with us.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
• To present the Site and its contents to you.
• To notify you about changes to the Site or any products or services we offer or provide though it.
• To allow you to participate in interactive features on the Site.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.
We may also use your information to contact you about our products and services that may be of interest to you. If you do not want us to use your information in this way, please use the opt-out procedures described in the Opt-Out Section.
Sharing Your Information
Circulus does not sell, trade, or disclose your personal information to third parties for their direct marketing purposes without your consent.
• To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Circulus assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by Circulus about the Site users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• To our affiliates.
• With your consent.
We may also disclose your personal information:
• To comply with any court order, law or legal process, including to respond to any government or regulatory request.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Circulus, our customers, or others.
We may disclose aggregated, non-personal information about the Site users, such as information gathered via cookies or other tracking technologies, without restriction.
If you do not wish to have your personal information collected, used, or sold by Circulus, you can opt out by filling out the form located at the Contact Us page or by contacting us at firstname.lastname@example.org.
If we have sent you a promotional email, you may send us a return email asking to be omitted from future promotional email distributions. This opt-out does not apply to transactional emails regarding your transactions or updates to our policies.
Upon your request, we will also:
• Provide you copies of your personal information that we have collected and stored.
• Correct any personal information you believe is inaccurate or have Circulus complete personal information you believe is incomplete.
• Delete your personal information other than such information gathered in relation to any transaction with Circulus.
If you make a request, we will respond within one month after receipt of your request and either verify the personal information was deleted or explain why it has not been deleted.
Additionally, if you have questions or concerns about Circulus’s privacy practices, please contact us by filling out the form located at the Contact Us page or by contacting us at email@example.com.
The foregoing requests can be made by you or your authorized agent provided your authorized agent submits proof to Circulus when making the request that you gave the agent signed permission to submit the request.
Children’s Online Privacy Protection Rule (“COPPA”)
The Site is a general website and is not directed at children under the age of 13. Circulus does not knowingly collect personable information from children under the age of 13.
Circulus has implemented appropriate technical and organizational measures to secure your personal information from risk of loss, misuse, and alteration. Nevertheless, such security measures may not prevent all loss, misuse, or alteration of information on the Site, and Circulus is not responsible for any damages or liabilities relating to any such security failures, and you agree to waive any claim or demand you have against Circulus arising out of the same. By using the Site, you understand that there is a risk that data and communications, including email and other electronic communications, may be accessed by unauthorized third parties. The foregoing does not affect any liability that cannot be excluded or limited under applicable law.
Accessing and Correcting Your Information
Circulus email subscribers or job applicants may review or modify their contact information on file at the Site by filling out the form located at the Contact Us page or by contacting us at firstname.lastname@example.org. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Your California Privacy Rights
Under California law, a California resident with whom Circulus has an established relationship has the right to request certain information with respect any personal information Circulus may have shared with third parties for their direct marketing purposes, and the identities of those third parties, within the immediately preceding calendar year, subject to certain exceptions. In response to a written request, Circulus has provided a cost-free means above to opt out of such sharing.
If you exercise your rights under the California Consumer Privacy Act (“CCPA”), the California Online Privacy Protection Act (“CalOPPA”), or any other privacy law applicable to your interaction with the Site, Circulus will not discriminate against you for exercising those rights.
Transfer of Information to the United States
Information About Children
The Site is not directed to children under the age of 18 years. We will not request personally identifiable information from anyone whom we know to be under the age of 18. By using the Site, you represent and warrant that you are at least 18 years old. If we become aware that a customer is under the age of 18 and has registered or otherwise provided personally identifiable information, we will cancel the corresponding registration and remove his or her personally identifiable information.
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