Privacy Policy

The following gives you an overview of what happens to your personal information when you visit our website.

The controller for the processing of personal data on this website within the meaning of the EU General Data Protection Regulation (GDPR) is:

  • Circula GmbH
  • Lobeckstr. 30-35
  • 10969 Berlin
  • Germany

You can contact our Data Protection Officer at:

privacy@circula.com

1.  Server Logfiles

Type and Purpose of Processing:

When you access our website, information of a general nature is automatically collected. This information (server log files) includes:

  • IP address
  • date and time of the request
  • time zone difference to Greenwich Mean Time (GMT)
  • content of the request
  • access status/HTTP status code
  • amount of data transferred in each case
  • website from which the request originates
  • browser
  • operating system and its interface
  • language and version of the browser software.

The processing occurs for following purposes:

  • ensuring a trouble-free connection to the website
  • ensuring a smooth use of our website
  • evaluation of system safety and stability

Legal Basis:

Processing is carried out in accordance with Art. 6 para. 1 lit. f GDPR on the basis of our legitimate interest in improving the security, stability and functionality of our website.

Recipients:

Recipients of the data may be technical service providers who are responsible for the operation and maintenance of our website. As processors on behalf, the service providers are obliged to process the data only within the scope of our instructions.

Retention Period:

The server log files are deleted after 1 month at the latest.

Statutory or Contractual Requirement to provide Data:

The provision of the aforementioned personal data is neither required by law nor by contract. Without the IP address, however, the service and functionality of our website cannot be guaranteed.

2. Contact Form

Type and Purpose of Processing:

The data entered by you will be processed in order to contact you in order to answer your enquiry. For this purpose, it is necessary to provide your name, a valid e-mail address. Optionally you can provide us with the name of your company.

Legal Basis:

If you contact us with the intention purchase services, the processing of the data entered in the contact form occurs for conducting pre-contractual measures (Art. 6 para. 1 lit. b GDPR).

If you contact us with general questions, we will process your data in accordance with Art. 6 para. 1 lit. f GDPR on the basis of our legitimate interest

Recipient:

The recipients of the data are processors on behalf. As contract processors, the service providers are obliged to process the data only within the scope of our instructions.

Retention Period:

If no user relationship is established after contact, your data will be deleted at the latest 6 months after the last contact.

If a contractual relationship is concluded, your contact data will be stored as long as the user relationship lasts. If we are subject to legal retention periods, we will comply with these and delete your data after the expiry of these periods.

Statutory or Contractual Requirement to provide Data:

If you wish to conclude a service agreement with us, the data provided by you is necessary for the conclusion and the performance of the contract.

Otherwise, the provision of your personal data is voluntary. However, we can only process your request if you provide us with the above data.

3.  E-Mail Contact

Type and Purpose of Processing:

We offer you the possibility to get in contact with us directly via e-mail. The data entered and transmitted by you will be processed exclusively for the purpose of individual communication with you. We will process your e-mail address as well as any information you share with us within communications.

Legal Basis:

The processing of data transmitted by e-mail is based on a legitimate interest (Art. 6 para. 1 lit. f GDPR) in efficient and simple communication with you.

Depending on the nature of your request, the processing of data transmitted by e-mail may serve to carry out pre-contractual measures (Art. 6 para. 1 lit. b GDPR).

Recipient:

The recipients of the data are processors on behalf. As contract processors, the service providers are obliged to process the data only within the scope of our instructions.

Retention Period:

If no user relationship is established after contact, your data will be deleted at the latest 6 months after the last contact.

If a contractual relationship is concluded, your contact data will be stored as long as the user relationship lasts. If we are subject to legal retention periods, we will comply with these and delete your data after the expiry of these periods.

Statutory or Contractual Requirement to provide Data:

The provision of your personal data is voluntary. Without transmission of data we cannot answer your inquiry however.

4.  Chat

Type and Purpose of Processing:

We offer you the possibility to get in contact with us directly via a chat window on our website. The data entered and transmitted by you will be processed exclusively for the purpose of individual communication with you. In order to offer the chat functionality we use a cookie.

We will process your IP-Address as well as any information you share with us within communications.

Legal Basis:

The processing of data transmitted by e-mail is based on a legitimate interest (Art. 6 para. 1 lit. f GDPR) in efficient and simple communication with you.

Depending on the nature of your request, the processing of data transmitted by e-mail may serve to carry out pre-contractual measures (Art. 6 para. 1 lit. b GDPR).

Recipient:

The recipients of the data are processors on behalf. As contract processors, the service providers are obliged to process the data only within the scope of our instructions.

Retention Period:

If no user relationship is established after contact, your data will be deleted at the latest 6 months after the last contact.

If a contractual relationship is concluded, your contact data will be stored as long as the user relationship lasts. If we are subject to legal retention periods, we will comply with these and delete your data after the expiry of these periods.

Cookie data will be deleted according to the cookie table below.

Statutory or Contractual Requirement to provide Data:

The provision of your personal data is voluntary. Without transmission of data we cannot answer your inquiry however.

5.  User Account / Test Account

Type and Purpose of Processing:

You can register on our website in order to access additional functions offered here. The input data will only be used for the purpose of using the respective site or service for which you have registered. The mandatory information requested during registration must be provided in full.

Otherwise, we will reject your registration.

Necessary information includes:

  • first and last name
  • e-mail address
  • company

Legal Basis:

The processing of data is based on the provision of a service contract (Art. 6 para. 1 lit. b GDPR).

Recipient:

The recipients of the data are processors on behalf. As contract processors, the service providers are obliged to process the data only within the scope of our instructions.

Retention Period:

Your contact data will be stored as long as the user relationship lasts. If we are subject to legal retention periods, we will comply with these and delete your data after the expiry of these periods.

Statutory or Contractual Requirement to provide Data:

The provision of your personal data is necessary for the performance of the service contract with us.

6.  Newsletter

Type and Purpose of Processing:

We offer you the possibility to register for a newsletter from us, in order to receive updates and news from us. We will need your name and a valid e-mail address for you to sign up to our newsletter.

Legal Basis:

The data is processed on the basis of the user's consent (Art. 6 Para. 1 lit. a GDPR).

Recipient:

The recipients of the data are processors on behalf. As contract processors, the service providers are obliged to process the data only within the scope of our instructions.

Retention Period:

We will process your information as long as you are subscribed to and consent to our newsletter.

Statutory or Contractual Requirement to provide Data:

The provision of your personal data is voluntary. Without transmission of data we cannot answer your inquiry however.

Right to Withdraw Consent:

You can withdraw your consent at any time by clicking the unsubscribe link located in every newsletter. Alternatively, you can e-mail us or contact us via our contact form.

7.  Website Analysis

Type and Purpose of Processing:

This website uses technology based on cookies to help us better understand how the website is used. We do this by compiling reports about activity on the site that do not identify specific individuals. In order to protect your privacy, if available your IP-Address is anonymized by the service provider. Analysis cookies transmit your IP address to service providers.

Legal Basis:

The data is processed on the basis of the user's consent (Art. 6 Para. 1 lit. a GDPR).

Recipient:

The recipients of the data are processors on behalf. As contract processors, the service providers are obliged to process the data only within the scope of our instructions.

Retention Period:

Cookie data will be deleted according to the cookie table below.

Statutory or Contractual Requir­­­ement to provide Data:

The provision of your personal data is voluntary, solely on the basis of your consent. If you prevent access, this may result in functional restrictions on the website.

Right to Withdraw Consent:

You can withdraw your consent at any time by clicking OPT OUT LINK.

An opt-out cookie will be installed on your device. This will prevent collection in the future as long as the cookie remains installed in your browser.

Furthermore, you may also use not tracking settings in your browser or plugins to prevent the use of cookies.

8.  Conversion Tracking, Custom Advertisement and Audiences

Type and Purpose of Processing:

This website uses technology based on cookies and pixels to help us better deliver advertisement content to website users and prospective clients.

With the help cookies and pixels, we are able to determine visitors of our website as a target group for the display of advertisements (so-called "customized ads").

We aim to only display advertisement to users who have shown an interest in our services or who have certain characteristics (e.g. interests in certain topics or products that may be determined on the basis of websites previously visited). To this end we use so-called "custom audiences" services offered by service providers to target specific interest groups.

With the help of pixels and cookies used, we can furthermore track the effectiveness of ads by seeing if users were referred to our website after clicking on a certain ad (so-called "conversion").

The following data is transferred via pixels and/or cookies:

  • IP-Address
  • HTTP-Header - Everything that is present in HTTP headers. HTTP headers are a standard web protocol that is sent between any browser request and any server on the Internet. HTTP headers include IP addresses, information about the web browser, page location, document, referrer, and person using the site.
  • Pixel Specific Data - Contains pixel ID.
  • Button Clicking Data - Contains all buttons clicked by website visitors, the names of those buttons, and any pages visited as a result of button clicks.

Legal Basis:

The data is processed on the basis of the user's consent (Art. 6 Para. 1 lit. a GDPR).

Recipient:

The recipients of the data are processors on behalf. As contract processors, the service providers are obliged to process the data only within the scope of our instructions.

Retention Period:

Pixel data is stored for up to 28 days.

Cookies data is deleted according to the cookie table below.

Statutory or Contractual Requirement to provide Data:

The provision of your personal data is voluntary, solely on the basis of your consent. If you prevent access, this may result in functional restrictions on the website.

Right to Withdraw Consent:

You can withdraw your consent at any time by clicking OPT OUT LINK.

An opt-out cookie will be installed on your device. This will prevent collection in the future as long as the cookie remains installed in your browser.

9. Cookies

Some of our web pages use cookies. Cookies do not harm your computer and do not contain any viruses. Cookies help make our website more user-friendly, efficient, and secure. Cookies are small text files that are stored on your computer and saved by your browser.

Most of the cookies we use are so-called "session cookies." They are automatically deleted after your visit. Other cookies remain in your device's memory until you delete them. These cookies make it possible to recognize your browser when you next visit the site.

You can configure your browser to inform you about the use of cookies so that you can decide on a case-by-case basis whether to accept or reject a cookie. Alternatively, your browser can be configured to automatically accept cookies under certain conditions or to always reject them, or to automatically delete cookies when closing your browser. Disabling cookies may limit the functionality of this website.

Cookies which are necessary to allow electronic communications or to provide certain functions you wish to use (such as the shopping cart) are stored pursuant to Art. 6 paragraph 1, letter f of DSGVO. The website operator has a legitimate interest in the storage of cookies to ensure an optimized service provided free of technical errors. If other cookies (such as those used to analyze your surfing behavior) are also stored, they will be treated separately in this privacy policy.

10.  SSL-Encryption

In order to protect the security of your data during transmission, we use state-of-the-art encryption procedures (e.g. SSL) via HTTPS.

11.  Processors on Behalf

The following organizations, companies or persons have been commissioned by the operator of this website to process data:

Facebook Ireland Limited

4 Grand Canal Square, Dublin, Ireland Dublin 2

Google Ireland Limited

Google Building Gordon House

4 Barrow St, Dublin, D04 E5W5, Ireland

Google LLC

1600 Amphitheatre Parkway, Mountain View, California, U.S.

Intercom

2nd Floor, Stephen Court,

18-21 St Stephen's Green, Dublin, D02 N960, Ireland

55 2nd Street 4th Floor, San Francisco HQ, U.S.

LinkedIn Unlimited Company

70 Sir John Rogerson's Quay,

Dublin 2, , Ireland

1000 W Maude Ave, Sunnyvale HQ, U.S.

Hubspot Inc.

Ground Floor, Two Dockland Central,

Guild St, North Dock, Dublin, D01 R8H7, Ireland

25 First Street, 2nd Floor Cambridge, MA 02141, USA

Hotjar Ltd

Hotjar Ltd, Level 2, St Julians Business Centre,

3, Elia Zammit Street St Julians STJ 3155, Malta, Europe

Mouseflow

Flaesketorvet 68, 1711 Copenhagen V, Denmark

1250 S Capital of Texas Hwy

Bldg 3, Suite 400, Austin, TX 78746, United States

Mixpanel Inc.

405 Howard St., 2nd Floor, San Francisco, CA 94105[SM1] [BB2]

12. Your Rights as a Data Subject

At info@circula.com you can exercise the following rights at any time:

  • Information about your data stored by us and its processing (Art. 15 GDPR),
  • Correction of inaccurate personal data (Art. 16 GDPR),
  • Deletion of your data stored with us (Art. 17 GDPR),
  • Restriction of data processing if we are not yet allowed to delete your data due to legal obligations (Art. 18 GDPR),
  • Objection to the processing of your data by us (Art. 21 GDPR) and
  • Data transferability if you have consented to data processing or have concluded a contract with us (Art. 20 GDPR).

If you have given us your consent, you can revoke it at any time with effect for the future.

You may at any time file a complaint with a supervisory authority, e.g. the competent supervisory authority of the federal state in which you reside or the authority responsible for us.

13.  Changes to the Privacy Policy

We reserve the right to adapt this data protection declaration so that it always corresponds to the current legal requirements or to implement changes to our services in the data protection declaration, e.g. when introducing new services. The current data protection declaration applies to every visit.

Version 1.1, November 2019