Privacy Policy

INTRODUCTION

The operators of this website are committed to protect the privacy of our clients / visitors, and to provide a safe and secure user experience. We will ensure that the information you submit to us via our website or through any of our offices is only used for the purposes set out in this policy. Thus, through this notice the Company shall explain when and why we collect personal information about people who visit our website and use our services, about how we use it, about the conditions where we may use to disclose it as well as how to keep it secure.

We may change this notice from time to time. By using our website, you are bound by this notice.

This privacy policy is provided in a layered format so you can click through to the specific areas set out below.

  1. Important information and who we are
  2. The data we collect about you
  3. How is your personal data collected?
  4. How we use your personal data
  5. Disclosures of your personal data
  6. International transfers
  7. Data security
  8. Data retention
  9. Your legal rights
  1. IMPORTANT INFORMATION AND COMPANY INFORMATION

PURPOSE OF THIS PRIVACY POLICY

This privacy policy aims to give you information on how CircleDesk Limited collects and processes your personal data through your use of this Website, including any data you may provide through this Website Contact Us Form. 

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

CONTROLLER

This privacy policy is issued on behalf of CircleDesk Limited.  CircleDesk Limited is the data controller and responsible for this website. Data Controller means the company that determines the means and purposes of processing of personal data.

THIRD PARTY LINKS

This website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Website, we encourage you to read the privacy policy of every website you visit.

  1. THE DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • “Identity Data” includes first name, last name, or similar identifier (only collected via Contact Form)
  • “Contact Data”: includes email address and telephone numbers (only collected via Contact Form)
  • “Technical Data” includes internet protocol (IP) address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to access this Website

We also collect, use and share “Aggregated Data” such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data) nor do we collect any information about criminal convictions and offences.

IF YOU FAIL TO PROVIDE PERSONAL DATA

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you.

  1. HOW IS YOUR PERSONAL DATA COLLECTED?

We use different methods to collect data from and about you including:

  • Direct interactions. You may give us your Identity Data, Contact Data and Employment related Data by sending us an email when you fill in the Contact Form.
  • Automated technologies or interactions. As you interact with our Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this data by using cookies, server logs and other similar technologies.
  • Publicly available sources. We may partner with publicly available sources (like content providers and analytics companies e.g. Google Analytics) to help us improve the services of the Website and better understand how you interact with the Website, as well as support our initiatives. These companies may collect information from you automatically in connection with your visit.
  • Third party sources. We may also collect personal data from third party sources, including data companies, publicly accessible databases, joint marketing partners, social media platforms and other third parties. We may also receive personal data about you from third parties when we need to confirm your contact details or even certain financial information. Should this be the case, and when acting as a data controller, we will take all measures as required by law to further inform you about the source of such personal data as well as the categories of personal data we collect and process. There are certain instances at law where we are specifically forbidden from disclosing to you such activity. 
  • When acting as a data processor, CircleDesk Limited processes personal data on behalf of one or more data controllers. In such cases it is the data controller’s obligation to provide data subjects with the said information. In case of uncertainty over who is the data controller, please contact us at the details provided in the Contact Page.

For a detailed description of the reasons why we process (as a data controller) the categories of personal data above (and any other specific personal data we process) as well as the corresponding legal ground(s) for doing so please see the ‘How we use your personal Data’ below.

For information/personal data that we may collect automatically via the site (as a data controller), please see the Cookie Policy.

  • Social Media. If you choose to connect one or more of your social media accounts with our site (if this option is available) to enable the sharing of personal data via social media platforms, certain categories of personal data relating to you from your social media account(s) will be shared with us.
  1. HOW WE USE YOUR PERSONAL DATA
  2. We may collect, use, store and transfer different kinds of personal information about you as follows and use it for a variety of different purposes and across various professional services we provide to you.
Information typeExample of how we use it
Address, email address, telephone numbers.We use this information to perform our professional services as instructed, to send you marketing information about events, updates and services and to respond to your queries.
Name, date of birth, Social Security Number, marital status, nationality, driving licence, passport.We use this information to perform our professional services as instructed and to verify your identity and to comply with our obligations under anti-money laundering legislation.
Occupation and income details such as employer name, employment status, your salary, other incomes & benefits, expenses. Information concerning marital and family status. Bank Account Statements.We use this information to perform our professional services as instructed and for future employment with the firm where applicable.
Creditors & Suppliers ListingsWe use this information to perform our professional services as instructed.
Interactions with our staff and partners.We use this information to keep a record of your interactions with us, to monitor and train our staff or to provide you with professional services.
Information on your trade union membership, health insurance membership, criminal offences/convictions.   We use this information to provide our professional services as instructed or for the establishment, exercise or defence of legal claims where applicable.

COOKIES          

This website does not collect any personal information through Cookies. For further information refer to the Cookie Policy. 

Google Analytics

We may use Google Analytics as well as any other analytics providers that we may use from time to time. We, and third parties like Google, use first party cookies and third-party cookies to inform, optimise and serve ads based on your past visits to our website:

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Website. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.

You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page (https://adssettings.google.com/authenticated). Google also recommends installing the Google Analytics Opt-out Browser Add-on for your browser (https://tools.google.com/dlpage/gaoptout). Google Analytics Opt-out Browser Add-on provides clients / visitors with the ability to prevent their data from being collected and used by Google Analytics.

Facebook Conversion Tracking Pixel

We may from time to time use Facebook (Visitor Action Pixel). This tool allows user behaviour to be tracked on Facebook and through the collection of this data, we can generate reports and statistics. The data collected remains anonymous and we cannot see the personal data of any individual user. However, this data is collected and processed by Facebook, which may link this information to your Facebook account. For more information https://developers.facebook.com/docs/facebook-pixel/implementation/conversion-tracking/

CHANGE OF PURPOSE

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose or where the law otherwise requires, as may be the case.

Please note that we may process your personal data without your knowledge or consent in the limited situations where this is required or permitted by law.

  1. DISCLOSURES OF YOUR PERSONAL DATA

We may share your personal data with the parties set out below for the purposes set out in the table above.

Your personal data may be shared with third parties on a need to know basis. This may include:

  • Parent or subsidiary companies of CircleDesk Limited.;
  • Individuals within the Human Resources Team at CircleDesk Limited as necessary.

Any potential acquirer, successor, or assignee as part of any proposed merger, acquisition, sale of assets, or similar transaction in which information is required to be transferred to one or more third parties as part of such transaction.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

  1. INTERNATIONAL TRANSFERS

As a general rule, the data we process about you (collected via the site, any of our apps or otherwise) will be stored and processed within the European Union (EU)/European Economic Area (EEA) or any other non-EEA country deemed by the European Commission to offer an adequate level of protection.

In some cases, it may be necessary for us to transfer your personal data to a non-EEA country not considered by the European Commission to offer an adequate level of protection (for example to one or more of our data processors located there). In such cases, you are assured that we have contractually bound such third-parties to adhere to EU laws pertaining to the protection of personal including but not restricted to the General Data Protection Regulation (Regulation 2016/679(EU)).

  1. DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  1. DATA RETENTION

HOW LONG WILL YOU USE MY PERSONAL DATA FOR?

We will retain your personal data only for as long as is necessary (taking into consideration the purpose for which it was originally obtained). The criteria we use to determine what is ‘necessary’ depends on the personal data in question and the specific relationship we have with you (including its duration).

Our normal practice is to determine whether there is/are any specific EU and/or local law(s) permitting or even obliging us to keep certain personal data for a certain period of time (in which case we will keep the personal data for the maximum period indicated by any such law). 

We would also have to determine whether there are any laws and/or contractual provisions that may be invoked against us by you and/or third parties and if so, what the prescriptive periods for such actions are (this is usually five (5) years, in line with prevailing and relevant legislation). In the latter case, we will keep any relevant personal data that we may need to defend ourselves against any claim(s), challenge(s) or other such action(s) by you and/or third parties for such time as is necessary.

Where your personal data is no longer required by us, we will either securely delete or anonymise the personal data in question.

In some circumstances you can ask us to delete your data: see Your Legal Rights below for further information.

In the case we do not delete your data, we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

  1. YOUR LEGAL RIGHTS

You have certain rights under the law with regards to how your personal information is processed. These rights are:

  • The right to be informed how your personal information is being used.
  • The right of access to your personal information.
  • The right to rectification if your personal information is incorrect.
  • The right to erasure your personal information. (Where the law permits this)
  • The right to restrict processing of your personal information
  • The right to data portability.
  • The right to object to how your personal information is used.
  • Rights in relation to automated decision making and profiling.

If you would like to make a request for information, please do not hesitate to contact us. 

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 could 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 could 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.