COLLECTION OF INFORMATION:
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.
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.
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.
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.
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.
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.
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/
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:
Post: Circle Media, Inc,
Last Updated: September 25 2014
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