CIRCLE MEDIA PRIVACY POLICY:

Circle Media, Inc. (“Circle,”  “ICAMAG,”  “we,” “us,” or “our”) knows that you care about how your personal data is used and shared, and we take your privacy very seriously.  This Privacy Policy addresses Circle’s practices regarding information collected from visitors of the website operated by Circle and located at www.circlemedia.com, www.icamag.com (the “Site” or “Sites”), and the ICA Mag Mobile and Tablet application.

This Privacy Policy only addresses information collected directly through or from the Site, Tablet and Mobile applications, it does not address or govern any information-gathering, use, or dissemination practices related to information collected from the visitor (sometimes referred to as a “visitor,” “you” or “your”) other than directly through or from the Site, such as from telephone, facsimile, postal mail, personal delivery, or other or additional offline means or media.

If you have any questions concerning this Privacy Policy, please contact Circle by email to privacy@circlemedia.com.

COLLECTION OF INFORMATION:

User Consent:  By submitting Personal Data through our Site or Services, including the Circle App or API, or Developer Apps, you agree to the terms of this Privacy Policy, you expressly consent to the collection, use and disclosure of your Personal Data in accordance with this Privacy Policy, and you represent and warrant that you have all rights necessary to submit such Personal Data.

TYPES OF DATA WE COLLECT:

“Personal Data” means data that allows someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, birth date, age, gender, company, job title, photos, website urls, social network handles, instant messenger handles as well as any other non-public information about you that is associated with or linked to any of the foregoing data.

“Public Data” means data from publicly available sources, such as via the Internet and social networks, including through public or licensed APIs .

“Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. We collect Personal Data, Public data, and Anonymous Data, as described below.

We may collect, and we allow third parties to collect, information about how you use and interact with our Site and Services. For example, we use Google Analytics.

We do not collect data from webpages that have been designated (in a standards-based way) as private.

We receive and store certain types of information whenever you interact with us. Circle and its authorized agents automatically receive and record certain “traffic data” on their server logs from your browser including your IP address, cookie information, and the page you requested. Circle uses this information to help diagnose problems with its servers, analyze trends and administer the website. Circle may also collect and display the total counts that page has been viewed. Many companies offer programs that help you to visit websites anonymously. While circle will not be able to provide you with a personalized experience if we cannot recognize you, we want you to be aware that these programs are available.

Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser to enable our systems to recognize your browser and tell us how and when pages of the Site are visited and by how many people. Circle cookies do not collect personal information; however, we may combine information collected through cookies with other personal information to tell us who you are or the identity of your account or e-mail address. As further described below, Circle’s advertising partners may also place a cookie on your browser that makes it possible to collect anonymous non-personally identifiable information that ad delivery systems use to present more relevant ads.

The “help” portion of the toolbar on the majority of browsers will direct you on how to prevent your browser from accepting new cookies, how to command the browser to tell you when you receive a new cookie, or how to fully disable cookies. Circle does not override these settings or options, including any “Do Not Track” settings, and encourages you to use them to enhance your choices and personalize your experiences.

The Site is not intended for children under the age of 13. It does not knowingly collect personal information online from visitors in this age group, and will delete information from a person in that age group as quickly as possible upon receipt of notice that such information has been collected.

USE OF INFORMATION COLLECTED:

Personal Data collected by Circle may be used by Circle for limited purposes, including the creation of an “Account Profile”, recordkeeping, editorial and feedback purposes, content improvement, or to customize the content and layout of the Site. Account Profile Data and other personal information voluntarily provided to Circle may be added to Circle’s databases and used for future contact regarding updates to the Site or new services provided by Circle. From time to time, Circle may need to contact you concerning information you submitted to Circle. You agree that Circle may use your Account Profile Data for such contact with you. Circle may also send out e-mails with news, products, offers, surveys or promotions that Circle believes may be of interest to you.

Circle personnel may have access to user information if deemed necessary in the normal course of Circle business. In some cases, we may choose to buy, sell or acquire assets. In these types of transactions, user information is typically one of the business assets that is transferred. Moreover, if Circle, or substantially all of its assets, were acquired, user information would be one of the assets that is transferred. We may also release Account Profile Data when we believe in good faith that release is necessary to comply with a law; to enforce or apply our Terms & Conditions, Additional Terms, and other policies; or to protect the rights, property, or safety of Circle, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

HOW WE COMBINE DATA:

We may process your Account Profile Data for purposes of cookie tracking, ad exchanges, ad networks, or sending electronic communications (including email).

We may share your Account Profile Data or disclose your Account Profile Data to third party partners. We may combine your Account Profile Data with Public Data to create more complete data record (“FanDex Profile Data”). We may use your Account Profile Data to make data associations between data elements and disclose these data elements as FanDex Profile Data even if the data association was previously undisclosed.

For example, if a person has a twitter handle, an email address and a facebook page, all of which constitute Public Data, and you provide Account Profile Data that includes the data association to tie those three elements of Public Data together, we may disclose that connection.  Further, nothing shall restrict our right to use, access, process, collect, disclose, share or distribute any Public Data or FanDex Profile Data, even if such Public Data or FanDex Data is duplicative of your Account Profile Data.

THIRD-PARTIES:

The Site may also contain links to third-party websites. The Site may contain links to other websites for the convenience of users in locating information, products, or services that may be of interest. If you access a third-party website from a link on this Site, any information you disclose on that website is not subject to this Privacy Policy. It is possible that these links may be used by third-parties or others to collect personal or other information about you. Circle is not responsible for the privacy practices of such websites, advertisers, or third-parties or the content of such websites and it is your sole obligation to review and understand the privacy practices and policies of these other websites. Circle does not control these third-parties’ use of cookies, collection of information, or how they manage such information. It is solely your obligation to review and understand the privacy practices and policies of these other websites, advertisers and any third-parties.

SECURITY MEASURES:

Security of Your Personal Data: Circle is committed to protecting the security of your Personal Data. We use a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. We also require you to enter a password to access your Account Profile Data. Please do not disclose your account password to unauthorized people.

Please be advised that the confidentiality of any communication or material transmitted to Circle via the Site or e-mail cannot be and is not guaranteed, including, for example, personal data such as your address or name. You acknowledge that the technical processing and transmission of the Site’s content may be transferred unencrypted and involve: (a) transmissions over various networks; and (b) changes to conform and adapt to technical requirements of connecting networks or devices. Accordingly, Circle is not responsible for the security of information transmitted via the Internet. Instead of communicating with Circle via e-mail or the Internet, visitors can contact Circle at the phone number or address set forth above.

OPT-OUT RIGHT:

Except as necessary to obtain the services or information requested, you may opt out of having your Personal Data, which has been voluntarily provided to Circle through online forms, e-mail, or another online avenues, prospectively retained by Circle or used by Circle for secondary purposes, by contacting Circle through one of the contact methods set forth above. Unless otherwise set forth below, this provision does not apply to collection of the type of web browser used to visit the Site or to information provided or collected that does not meet the description hereunder.

ACCESS, CORRECTION, and DELETION:

Circle allows individuals to access, modify, and set permissions with respect to their Account Profile Data that it holds about them. If you choose to connect your Circle account with one of our development partners, you may be giving the partner access to your Personal Data and Public Data. We will tell you how the partner application will access your account and you can turn off access whenever you want. You may access and make choices about your Account Profile Data by choosing to edit your profile on the Circle Site at my.icamag.com.  If you update or edit your profile and set any of the data elements about you to ‘disabled’, any additional data about you that we thereafter collect from third parties will be designated as ‘disabled’ unless you specify otherwise. If you request that we delete your Account Profile or FanDex Profile Data, we will not do so because, if we do, we may recollect your contact information and we will not have a record that you requested that your contact information be deleted. Instead of deleting your contact information from your systems, we will retain it but flag it to not be used or shared with third parties.

DATA INTEGRITY:

Circle will use Personal Data only in ways that are compatible with the purposes for which it was collected or subsequently authorized by you. Circle will take reasonable steps to ensure that Personal Data is relevant to its intended use, accurate, complete, and current. Circle depends on you to update and correct your Personal Data to the extent necessary for the purposes for which it was collected and subsequently authorized by you.

ENFORCEMENT:

Circle conducts periodic self-assessments to verify that the attestations and assertions it makes about its privacy practices are true and that such privacy practices have been implemented as presented. Circle will take steps to remedy any problems arising out of failure to comply with the Safe Harbor principles.

DISPUTES: 

Circle takes its users’ privacy concerns seriously. If you believe that Circle has not adhered to this Privacy Policy, please contact Circle as described in below. In your email, please describe in as much detail as possible the ways in which you believe that this Privacy Policy has not been complied with. We will do our best to address your concerns. If you feel that your complaint has been addressed incompletely, we invite you to let us know for further investigation.

DISPUTE RESOLUTION FOR USERS OUTSIDE OF THE UNITED STATES:

The following provision only applies to you if you are a resident in the European Economic Area. Circle has further committed to refer unresolved privacy complaints under the US-EU and US-Swiss Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Circle, please visit the BBB EU SAFE HARBOR web site at http://www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

DIGITAL ADVERTISING:

Although it is our hope that you find the display of advertising to you based on your anonymous interests valuable, if you would prefer not to participate in the services offered through these solutions, you can always opt-out of this activity by visiting the Network Advertising Initiative (NAI) website by clicking here. *If the link isn’t working properly, copy and paste this URL into a new browser window: http://www.networkadvertising.org/choices/

CHANGES TO THIS PRIVACY POLICY:

Circle may amend this Privacy Policy from time to time, at its sole discretion. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. Your use of the Site following any changes means that you agree to follow and be bound by the Privacy Policy as changed. Any change to this Privacy Policy shall be effective as to any visitor who has visited the Site before the change was made. It is the obligation of users visiting the Site before the change to learn of changes to the Privacy Policy since their last visit.

CALIFORNIA RESIDENTS PRIVACY POLICY:

California Civil Code Section 1798.83 (also known as the “Shine The Light” law) permits users who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third-parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third-parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request by email or post to:

Email:        privacy@circlemedia.com

Post:          Circle Media, Inc,

85 5th Avenue, 12th Floor, New York City, NY 10003 Attn: Website Privacy Policy/CA Privacy Rights.

Last Updated: September 25 2014

Copyright © 2014 Circle Media, Inc.; All rights reserved.