Privacy Policy

This privacy notice (hereafter referred to as Notice) provides information on how the software solution for travel expense management Circula (hereafter referred to as ‘Circula’) processes the personal data that you provide to us or that we collect from you during your use of Circula.

Please read through this notice carefully. By using Circula, you consent to the processing of your personal data in accordance with these notices. If you do not want your personal data to be processed in the manner described in this notice, please refrain from using Circula.

You can use Circula either through www.circula.com (hereafter referred to as Website) or our mobile application (hereafter referred to as App) on your mobile device.

Which personal data is collected and processed?

Personal data are details of personal or factual relations of a specific or identifiable natural person. This includes, for example, information such as a name, postal address, e-mail address or telephone number, and possibly also usage data such as the IP address.

If you register for Circula, you must provide the following personal information:

  • Name and surname
  • E-mail address (specifically your company e-mail address)
  • Credit card number (optional; this is only for your company credit card; this data is only collected if your employer provides you with a credit card for business purposes)
  • Your employee ID (optional)
  • Details relating to payments made with your company credit card, such as the payee, the date and the time of the transaction

In addition, you can use Circula to transfer certain details, which are required for travel expense calculation, directly from a digital calendar you have authorized. These details can also include personal data (e. g. names of business partners from a business dinner). If you do not want this data to be accessed, please do not share the calendar.

Logging of data through Logfiles

For technical reasons, your Internet browser automatically transmits data to our web server when you access our website and app. This includes, but is not limited to the date and time of access, the URL of the linking website, the file accessed, the amount of data sent, the type and version of your browser, the operating system and your IP address. This data is stored separately as Logfiles from other data that you enter during the use of our website and app. This data will not be associated with a specific person unless we are requested to do so by a court of law. IP addresses are automatically deleted after a period of one month.

How we use Cookies

Cookies are used to give you the best possible user experience on the website. They are used, for example, so that you don't have to fill in the login form every single time you visit the website. Cookies are small text files that the website can store on the user's terminal device. They are saved locally. If you authorize the use of such cookies, they will be regularly stored on your end device for a period of 90 days.

You can deactivate the storing of cookies in your browser by preventing the installation of cookies in your browser settings ("private mode"). You can also delete cookies from your PC's hard drive at any time (folder: “Cookies"). You can also use our website without cookies, but please note that in this case, you may not be able to fully use all the functions of the website.

We also use the "Google Analytics" cookie, a web analysis service provided by Google Inc. (hereinafter: "Google"). The information generated by Google Analytics about your use of the internet platform is generally transferred to a Google server in the USA and stored there. However, we have enabled the activation of IP anonymization for the internet platform, so that your IP address will be shortened before being transferred to a server either by Google within member states of the European Union or in other contractual states of the European Economic Area Agreement. Only in exceptional cases will the full IP address be transferred to a Google server in the USA and shortened there. Google will use the information gained from the use of the internet platform to evaluate your use of the website, to create reports on website activity and to provide further services associated with the use of the website and the use of the internet to the website operator. The IP address, which is transmitted by your browser, will not be merged with other Google data in the context of Google Analytics. You can prevent the storing of cookies by setting your browser software accordingly; however, we would like to point out that in this case, you may not be able to use the full functionality of this website. To learn more about Google Analytics cookies, please click here: https://www.google.com/policies/technologies/types/ . You can prevent Google from collecting and processing the data generated by cookies and related to your use of the website (including your IP address) by downloading and installing the browser plug-in available at http://tools.google.com/dlpage/gaoptout?hl=en . As an alternative to the browser add-on or as a solution for browsers on mobile devices, please click this link to prevent Google Analytics from collecting data while you are on this website in the future (the opt-out only works in the browser and only for this domain). In doing so, an opt-out cookie is placed on your device. If you delete the cookies in your browser, you have to click this link again.

We are also using Google Conversion Tracking for the internet platform. Google will place a so-called "conversion cookie" on your computer if you have accessed the internet platform via a Google ad. These conversion cookies lose their validity after 30 days and are not used for personal identification. If you visit a Google AdWords customer's website and the conversion cookie has not yet expired, Google and the customer will be able to see that you clicked on the ad and were redirected to our Internet platform. Each Adwords customer receives a different conversion cookie. Conversion cookies, therefore, cannot be tracked via the websites of Adwords customers. The information gathered using the conversion cookie is used to generate conversion statistics for Adwords customers who have chosen to use conversion tracking. Adwords customers are notified of the total number of users who clicked on their ad and were redirected to a page marked with a conversion tracking tag. However, they do not receive any information that personally identifies users. If you do not wish to participate in the tracking procedure, you can also refuse to accept the necessary use of cookies - for example, via a browser setting that generally deactivates the automatic use of cookies. Google's privacy policy for conversion tracking is available at https://support.google.com/adwords/answer/1722022?hl=en .

We use Intercom's analysis service to better understand your use of our service. We provide Intercom, Inc. (" Intercom") a limited amount of your information (such as your email address and registration date) and use Intercom to collect information for analysis purposes when you visit our website or software solution. Intercom analyzes your use of our website and/or our software solution so that we can improve our service for you. We can also use Intercom as a medium for communication, either via e-mail or through direct messages within our products. As part of our service agreements, publicly available contact information and social data such as your email address, gender, company, job title, photos, website URLs, social network handles, and physical addresses are collected by Intercom to enhance your user experience. More information about Intercom's privacy practices can be found at https://www.intercom.com/terms-and-policies#privacy . The services of Intercom are subject to the terms of use of Intercom, which can be found at https://www.intercom.com/terms-and-policies#terms . If you do not want this information to be collected or disclosed by Intercom, please contact us.

Disclosure of data to third parties and service providers

Your personal data collected via the website and the app will only be passed on to third parties if this transmission is necessary for the rendering of services for travel expense invoicing.

If we commission external service providers with the processing of your personal data, which has not been collected by these service providers themselves, but which has been made available to them by us, the service providers will use the personal data exclusively within the scope of the contract given in accordance with our instructions (Customer Data Processing Agreement) and the provisions of these instructions. These service providers are Mixpanel, Inc. (https://mixpanel.com/), Mailjet GmbH (https://www.mailjet.de/), Pipedrive, Inc. (https://www.pipedrive.com/de), Chargebee, Inc. (https://www.chargebee.com/), Microsoft Corporation (https://www.microsoft.com) and Intercom Inc. (https://www.intercom.com/)

The disclosure of data to governmental institutions and authorities entitled to receive such information is either only carried out within the framework of the statutory disclosure obligations or if we are required to provide information by a court ruling.

Under no other circumstances will we pass on your personal data to third parties for advertising or marketing purposes, unless you expressly consent to this beforehand.

For which purposes is the collected personal data processed?

The processing of personal data provided by you is carried out by using the "Circula" software exclusively to enable you to invoice your business trips recorded via the Website or App. For other purposes, the personal data you have provided will not be processed.

Data storage length

We will store your personal data for as long as is necessary for the purposes for which it was collected in compliance with this Privacy Notice. However, we may be required by law to store certain data for a longer period. In this case, we will ensure that your personal data is treated in accordance with this Privacy Notice for the entire period.

Your Rights

You can request information free of charge about your personal data stored by us at any time without stating your reasons. You may at any time object to the collection and usage of your data without giving any reason and revoke your prior consent to the use of your data. If you revoke your consent to the processing of your data, we will no longer be able to provide services for you. Therefore, you will no longer be able to use Circula to invoice your travel expenses.

Moreover, you can have the data collected and stored by us corrected, updated, made anonymous, blocked, restricted or deleted. Furthermore, you can request that your data be passed on to third parties by us. To exercise your rights as described above and for all questions regarding your personal data, please contact privacy@circula.com.

Transfer of your personal data to the USA

If we disclose your personal data to service providers (Contract Data Processors) in the USA, these service providers are always certified with the US-EU-Privacy Shield.

Data Security

Our website is hosted on servers operated in Germany. We take the proper precautions to protect your personal data from unauthorized access. The data is stored in a certified data center on secure computers. The data is stored in encrypted form to the greatest extent possible. We regularly review our security policies and procedures to ensure the integrity of our systems. However, the transmission of data via the Internet to our Website cannot be guaranteed to be one hundred percent secure.

Changes to the Statement

In the context of a technical development of our offer and the legal framework, we may adjust our notice from time to time. Changes to the Privacy Notice will be published on the website and in our app. Therefore, please read the latest version of the notice regularly. Subject to applicable law, any changes to the notice shall become effective as soon as the updated notice has been published. If we have already collected your data and/or are subject to a legal obligation to provide information, we will inform you of any significant changes to our Privacy Notice and ask for your assent.

Updated: 20.09.2017

Privacy Statement for our Newsletter

Purpose of the newsletter

The newsletter from Circula GmbH is used to send information about travel expense accounting via e-mail.

The purpose of collecting and processing your personal data

To receive the newsletter, please provide us with your first and last name, and e-mail address. These details are personal data; the collection, processing, and use of which is subject to data protection regulations. This personal data is exclusively collected and utilized to send the newsletter.

As a prerequisite for receiving our newsletter, it is stated under data protection law that you must consent to the collection and processing of your personal data. You declare this consent upon registration by confirming your consent and acknowledging that you are aware of this data protection information.

Disclosure of data to third parties and service providers

Your personal data collected for the newsletter will only be passed on to third parties if this transfer is necessary for sending the newsletter.

If we commission external service providers with the processing of your personal data, which is not collected by these service providers themselves but made available to them by us, the service providers use the personal data exclusively within the scope of the contract given in accordance with our instructions (Customer Data Processing Agreement) and the provisions of these instructions. These service providers are Mixpanel, Inc. (https://mixpanel.com/), Mailjet GmbH (https://www.mailjet.de/), Pipedrive, Inc. (https://www.pipedrive.com/de), Chargebee, Inc. (https://www.chargebee.com/) and Microsoft Corporation.

The disclosure to government institutions and authorities entitled to receive such information is only carried out within the framework of the statutory disclosure obligations or if we are obliged to provide information by a court ruling.

Under no circumstances will we pass on personal data to third parties for advertising or marketing purposes, unless you expressly consent to this beforehand.

Storage length

We will keep your personal data for as long as it is necessary for the purposes for which it was collected in accordance with this Privacy Notice. However, we may be required by law to store certain data for a longer period. In this case, we will ensure that your personal data is treated in accordance with this Privacy Notice for the entire period.

Your Rights

You can obtain information free of charge about your personal data stored by us at any time without giving any reason. You can always object to the collection and usage of your data at any time without giving any reasons and revoke your prior consent to the usage of your data. If you revoke your consent to the processing of your data, we can no longer send you our newsletter.

Furthermore, you can have the data collected and stored by us corrected, updated, made anonymous, blocked, restricted or deleted. In addition, you can request that your data be passed on to third parties by us.

To exercise your rights as described above and for all questions regarding your personal data, please contact privacy@circula.com.

Data Security

Our website is hosted on servers operated in Germany. We take all the necessary precautions to protect your personal data from unauthorized access. The data is stored in a certified data center on secure computers. The data is stored in an encrypted form to the greatest extent possible. We regularly review our security policies and procedures to ensure the integrity of our systems. However, the transmission of data via the Internet to our Website cannot be guaranteed to be one hundred percent secure.

Transfer of your personal data to the USA

If we disclose your personal data to service providers (Contract Data Processors) in the USA, these service providers are always certified with the US-EU-Privacy Shield.

Changes to the Statement

In the context of further technical development of our offer and the legal framework, we may adjust our notice from time to time. Changes to the notice will be published on our website. Please read the latest version of the notice on a regular basis. Subject to applicable law, any changes to the notice shall become effective as soon as the updated notice has been published. If we have already collected your data and/or are subject to a legal obligation to provide information, we will inform you of any significant changes to our Privacy Notice and ask for your assent.

Updated: 10.12.2017