This privacy notice is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.
1 – Important Information
Circulator is committed to protecting your privacy. We have taken all the essential measures to make sure that any information you give us, remains private and secure and that your information is processed with total confidentiality. As required by the Irish Data Protection laws, we follow strict security procedures in the storage and disclosure of information, which you have given us, to prevent, unauthorised access.
Our contact details
Broadcasting House, 3A Princes St, Dublin 2, D02 A520
+353 1 4759299
DPO: David Traynor
2 – What type of information we store
We currently collect and process the following information:
- Personal identifiers, contacts and characteristics (for example, name and contact details)
- Company identifiers (website, industry)
3 – How we get the information and why we have it
Most of the personal information we process is provided to us directly by you for one of the following reasons:
- Signing up to our newsletter
- Providing your details over the phone
- Requesting a consultation
- Requesting a demo
- Requesting partnership
- Becoming a customer
We also receive personal information indirectly, from the following sources in the following scenarios:
- Through sales channels
- Via email introductions
Under the General Data Protection Regulation (GDPR), the lawful bases we rely on for processing this information are:
- Your consent. You are able to remove your consent at any time. You can do this by contacting firstname.lastname@example.org
- We have a contractual obligation.
- We have a legitimate interest. being the delivery of emails (newsletters, sales, demos, surveys, events and service notifications)
4 – What do we do with your information
We will process personal data relating to you for the purposes of:
- dealing with any queries that you have submitted to us via our website or our SaaS platform
- processing applications and transactions submitted through our website or our SaaS platform
- improving and developing our website and the services provided on our SaaS platform
- carrying out research and user surveys
- sending you promotional and marketing materials, subject to any preferences that you express when we collect your contact details or subsequently. You can opt out of receiving promotional and marketing materials from us at any time, including by contacting email@example.com
- generating and analysing statistics regarding usage of our website and SaaS platform, including the frequency of use of individual pages (where possible, personal data will be anonymised before being used for this purpose)
- fraud prevention, investigation and detection
- establishing, exercising or defending legal claims
- providing information to our professional advisors
Submitting website forms
We have a number of (entirely optional) data collection forms on the company website. These include the forms used by customers to “Book a Demo” or “book a consultation” or the “Contact Us” form. If you submit your details on the Request a consultation, Book a Demo form, Contact Us form, or any other similar form we may implement in the future, we will save your personal details in our Customer Relationship Management (CRM) database.
Other information submitted via the request for a demo or consultation form will be stored in our CRM system, and used by our sales or support people to make contact in relation to your request for a demo, consultation or other inquiry. We may use your information to contact you again in future if we believe we have an offer that may be relevant to you. We may also analyse collected contact information in aggregate form to better inform our future marketing efforts.
Browsing our website
As an anonymous visitor to our website we collect no personally identifiable information about you, apart from information which you volunteer (please see more on this in the next section below).
We use temporary third party Google Analytics cookies to collect an anonymous record of your site page views and to recognise return visits (also anonymously) using a unique cookie that Google Analytics stores in your browser.
We use the collected page-view information to understand how visitors use the website and to help us improve access to its information and functionality.
Subscribing to communications
We have a number of (entirely optional) subscription forms on our company website. These include, for example, subscribing to a newsletter. When you download content or register for an event via a form, you subscribe to our newsletter. We record and save your email address, whether you are a customer or prospective customer, in addition to your format preference. This data is used based on legitimate interest and to enable us to send you relevant email marketing. Circulator tracks email ‘opens’ using an invisible 1×1 pixel- unique image that is placed in each email sent by
our system i.e. not a cookie. These 1×1 pixel tags enable us to send email messages in a format customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.
If you receive the HTML formatted version of the newsletter and your email client is configured to download images, we will be notified each time you open the email, and this information will be saved with your subscriber record. We also record your clicks on links in the newsletter and in the companion website with your subscriber record.
Some of our newsletters may carry a survey and if you respond your answers are saved with your subscriber record and are used to prevent multiple entries by an individual. We use the stored open, click and survey information in aggregated form to give us an indication of the popularity of the content and to help us make decisions about future content and formatting. We may also use the information to publish more relevant content to individual newsletter readers in future issues.
You may choose to stop receiving our newsletters at any time by using the “unsubscribe” link included in every email sent. Your email address may be retained to ensure you no longer receive communications, unless you choose to actively re-subscribe.
Commenting on our blog
When you comment on our blog cookies are sometimes used, which means that sometimes you won’t need to retype all your information when you want to leave another comment.
5 – Data storage & retention
Personal information, such as collected on our company website, is securely stored in our servers and the servers of selected third-parties (Google, Zoho). We will never share personal information with other third parties, except where we are required to do so by law or for fraud prevention, investigation and detection, or, for establishing, exercising or defending legal claims.
We will only retain your personal data for as long as necessary to fulfil 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 unauthorised 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.
6 – International Transfers
Some of our external third parties and hosting is based outside the European Economic Area (EEA) so the processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
- Where we use certain service providers, we use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
7 – Your data protection rights
Under data protection law, you have rights including:
Your right of access – You have the right to ask us for copies of your personal information.
Your right to rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances.
Your right to restriction of processing – You have the right to ask us to restrict the processing of your information in certain circumstances.
Your right to object to processing – You have the right to object to the processing of your personal data in certain circumstances.
Your right to data portability – You have the right to ask that we transfer the information you gave us to another organisation, or to you, in certain circumstances.
Right to be forgotten – You have the right to request us to delete personal data that we hold about you. This is sometimes referred to as the “right to be forgotten”.
No fee usually required – 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.
What we may need from you – 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.
Time limit to respond – 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.
If you wish to exercise any of the rights set out above, Please contact us at firstname.lastname@example.org if you wish to make a request.
You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you. Our security procedures mean that we may occasionally require proof of identity before we are able to disclose sensitive or other information to you.
Please contact us at email@example.com if you wish to make a request.
8 – Changes to this Policy
9 – Contact Us
If you have any questions regarding the processing of your personal data and your GDPR rights or if you want to get a copy of the personal data that we hold for you, please contact us
Phone: 01 4759299
Address: Circulator, Broadcasting House, 3A Princes St. South, Dublin 2, Ireland
10 – How to complain
Data Protection Commissioner
21 Fitzwilliam Square South