Posted: December 1st, 2019
Effective:December 1st, 2019
Thanks for using CIRCULARO™ .
In this document, PALAXO EUROPE s.r.o., Identification No.: 068 64 988, with its registered office at Na Folimance 2155/15, Vinohrady, 120 00 Prague 2, registered in the Commercial Register maintained by the Municipal Court in Prague, Section C, File 290373 (“Palaxo or “We”) describes how we collect, use and handle your information when you use our websites, software, our Circularo service and/or other services ("Services").
We collect and use the following information to provide, improve and protect our Services:
We may share information as discussed below, but we won't sell it to advertisers or other third parties.
For how long will your information be retained
We'll retain information you store on our Services for as long as you use the Services or for as long as we need it to provide you the Services.
If you delete your account, we'll also delete this information promptly. However, we may not delete your account information promptly or at all, (1) if there is latency in deleting information from our servers and back-up storage or if (2) necessary to comply with our legal obligations, resolve disputes, or enforce our agreements.
To provide you with the Services, we may store, process and transmit information in the United States and locations around the world - including those outside your country. Information may also be stored locally on the devices you use to access the Services.
Palaxo is an ‘Administrator’ under Article 13 of the Regulation (EU) 2016/679 on the protection of natural persons with regard to the processing of personal data (“Regulation” or “GDPR”), which sets out important principles of personal data processing (“Principles”). The purpose of processing under these Principles is primarily the provision of the Services, including the operation of the circularo.com website, as well as marketing and other activities related to our business. These may be related but detailed information about each is set out below.
Providing Circularo Services
If you use Services relating to Circularo (“Circularo Services”), we process the personal data that we need to provide you with the Circularo Services to the extent and quality you are interested in.
Scope of Processing. Your personal data is processed only to the extent necessary and primarily includes the following categories of data:
We do not have access to Your Content unless you give us permission to access Your Content. We are a ‘Processor’, not an ‘Administrator’, with respect to Your Content.
Legal Basis of Processing. The legal basis for processing is:
Period of Processing. We process your personal data for as long as is needed. In particular:
Operation of the Circularo.com Website
If you visit any our websites, including www.palaxo.com or www.circularo.com (“Websites”) es other than to use Circularo Services (or before the use of these services), we process some of your personal data to ensure the smooth operation of the Websites, user comfort, and regular improvement. You can also contact us via our website to provide us with some of your personal data.
Scope of Processing. Your personal data is processed only to the extent necessary, depending on the extent to which you use our website. This mainly includes the following categories:
Legal Basis of Processing. The legal basis is our legitimate interest in monitoring the use and operation of our Websites, visitors, and user comfort. We also have a legitimate interest, if you contact us via forms on our Websites, in receiving feedback, tips, or suggestions from you or generating business .
Period of Processing. We process your personal data for as long as needed. In particular:
Related Business Activity. If you visit our Websites, or use Circularo Services, we also use some of your personal data for the purpose of our business activities as well as various forms of marketing; in particular, maintaining a database of customer contact data and business partners,.
Scope of Processing. The personal data is processed only to the extent necessary. This mainly includes the following categories:
Legal Basis of Processing. The legal basis is our legitimate interest in having knowing of our business partners in order to carry out our business activities, and our legitimate interest in marketingto increase awareness of the products and services that we offer. All this applies to a reasonable extent and with respect for the privacy of our business partners. The set of contacts is part of our know-how and enables us to carry out business activities efficiently in our field, and maintaining our know-how is also our legitimate interest.
Period of Processing. We process this personal data only until you object to it. If you submit your objections (or any statement that you are not interested in marketing or keeping of your contact data in our contacts list), we will erase this personal data, unless we have another legal basis to process it, and we will stop using it for that purpose. We will also inform you about the option of refusing marketing in every marketing communication.
Sharing of Personal Data
Third Parties. We do not process your personal data independently, but we do so in cooperation with trustworthy partners and suppliers. The categories of recipients include providers of technical support, cloud and web hosting solutions, suppliers in the field of marketing, accounting, legal, marketing, or similar consultants, as well as other persons with whom we cooperate.
Location. We process your personal data primarily in the European Union, but some of our processors and partners may be located outside the Czech Republic and the European Union. In this case, we make sure that they guarantee to the greatest extent possible that the personal data is protected and we act in accordance with the European Union law when dealing with them, in particular by using standard contractual clauses approved by the European Commission. In addition to the European Union, our partners may also be located in the United States of America, the United Arab Emirates, Australia, India, or other countries. In this case, however, full GDPR compliance at a high level and a high level of personal data protection is ensured when dealing with them.
Your Rights pursuant to the GDPR
Rights. In accordance with the GDPR, you have the right to correct or complete the incomplete personal data, request processing restriction, complain against the personal data processing, request personal data transfer, access your personal data, be informed of personal data leakage, request personal data deletion, and other rights as laid down by the GDPR.
Objections. You have the right to object to the processing based on the legitimate interest of the Administrator to the e-mail address above. If the objections relate to direct marketing, we will always accept these objections.
Withdrawing Consent. If you have ever given us consent, you can withdraw it at any time. This does not affect the lawfulness of processing prior to the consent withdrawal.
More Information. You can find more information on the GDPR rights on the website of the Office for Personal Data Protection. (https://www.uoou.cz/6-prava-subjektu-udaj/d-27276). We have not appointed a personal data protection officer, but you can always contact us as the Administrator by e-mail: email@example.com or by post to the address of our registered seat (Na Folimance 2155/15, Vinohrady, 120 00 Prague 2). We may require you to prove your identity to prevent unauthorised persons from accessing your personal data.
Complaints. You have the right to lodge a complaint to the supervisory authority regarding the personal data processing or the failure of the Administrator to fulfil the GDPR obligations. The supervisory authority is the Office for Personal Data Protection, with its registered office at Pplk. Sochora 27, 170 00 Prague 7, www.uoou.cz.
Transfer. If we are involved in a reorganization, merger, acquisition or sale of our assets, your information may be transferred as part of that deal. We will notify you of any such deal and outline your choices in that event.
Notices. Any communication sent by us under this Policy by email to the email address provided by you in connection with a Service.
Have questions or concerns about our Services and privacy? Contact us at firstname.lastname@example.org