Privacy Policy

YOUR PRIVACY IS IMPORTANT TO US

This privacy policy (“Privacy Policy”) describes the information collection policies and practices of Smart Circle International, LLC (sometimes referred to as “Smart Circle,” “us,” “we” or “our”) and may include its sister companies and other entities that are related to Smart Circle by common ownership. This Privacy Policy summarizes what information we might collect from a registered user or other visitor and what we will and will not do with it. We have established this Privacy Policy so that you are informed about how we treat any personal information that you may provide to us in the course of using this website.

The creation of this Privacy Policy grows from our fundamental respect for your right to privacy and will serve to guide our relationship with you. We value the privacy and security of your “personal information,” which as used herein means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household. As such, we take complying with data privacy and security laws very seriously.

The purpose of this Privacy Policy is to provide you with a description of our personal information collection, use, and disclosure practices. If you provide us with your personal information, or we obtain personal information about you from other sources, we treat your personal information according to this Privacy Policy.

HOW YOU ACCEPT THE TERMS AND UPDATES TO THE PRIVACY POLICY

You consent to and agree to be bound by this Privacy Policy by expressly accepting the terms of the Privacy Policy or by using this website. From time to time, we will update this Privacy Policy as we adopt new practices and procedures related to your personal information. Any changes to this Privacy Policy will be placed here and will supersede this version. If we make changes to this Privacy Policy, we will revise the “Last Updated and Effective Date” above and, in some cases, we may send you a notice of our changes as well if you have provided us your e-mail or mailing address.

THE PERSONAL INFORMATION WE COLLECT ABOUT YOU

We collect personal information that you voluntarily provide to us by e-mail or other methods of contact in order to access certain options and services. The personal information you may provide, and we may collect, include your name, company name, email address, phone number, and address.

We may also collect other information that cannot be readily used to identify you. For example, our web server may automatically store your Internet Protocol (“IP”) address and your domain (where possible) when you log onto our website, the e-mail addresses of those who communicate with us via e-mail, and the aggregate information about what pages on our website you visit or access.

THE REASON WHY WE COLLECT YOUR PERSONAL INFORMATION

We will use your personal information to respond to your inquiry or request or otherwise help in processing inquiries and requests. Our policy is to limit the information collected to only the minimum information required to complete a visitor’s request.

In addition, we may use information you may provide us for editorial purposes, and may use your name and any stories you provide us in articles published online and on our website. Please be advised that any such submissions become the property of Smart Circle and may be used by Smart Circle for any lawful purpose. If you provide us with personal anecdotes, they may be attributed to you. Smart Circle can edit, delete, rewrite, use, and reuse the content, including your name, likeness, photograph, and biographical information you provide, in any way and in any media whether now known or invented in the future, with or without attribution, including publication on this website, in magazines, and in trade media, and advertising. You agree that any content you send us will not violate any rights of any third party and that you will only send us content for which you own the rights.

WHETHER WE SHARE YOUR PERSONAL INFORMATION WITH OTHERS

Smart Circle is the sole owner of the information collected on our website and we do not sell to third parties. In certain circumstances, however, Smart Circle may share your information with service providers, such as Smart Circle’s vendors or business partners, in order to service you as a customer. We may provide your personal information that we collect and the data generated by cookies to a parent, subsidiary or affiliate entity, partner entities, and the vendors and service providers that we may engage to assist us. In addition, we may provide your personal information to an organization to complete a service, to assist us in reviewing the data or to provide marketing or advertising on our behalf. When we share your personal information with others (collectively, “Service Providers”), as described above, we do not sell the information.

We may also share your personal information if necessary to: (1) comply with federal, state, or local laws; (2) comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; (3) cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local laws; or (4) exercise or defend legal claims.

Lastly, we may transfer your personal information to a third party as an asset that is part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control of all or part of our business. Such successor entity shall be bound by the terms and conditions of this Privacy Policy.

HOW WE PROTECT YOUR PERSONAL INFORMATION

We have implemented and maintain reasonable security procedures and practices appropriate to the nature of the information to protect your personal information from unauthorized access and exfiltration, theft, or disclosure.

RETENTION OF PERSONAL INFORMATION

Your personal information will be retained for the time required to fulfil the purposes for which it was collected and processed, including for the purpose of satisfying legal, professional, contractual, regulatory, accounting or reporting obligations.

CHILDREN

This website and the products and services offered herein are not intended for or directed at children under the age of 13. In addition, we do not knowingly collect information from children under the age of 13.

E-MAIL COMMUNICATIONS

If the email address you provide to us is a wireless email address, you agree to receive messages at such email address from Smart Circle and affiliated entities (unless and until you have elected not to receive such messages by notifying us at webinquiry@thesmartcircle.com). You understand that your wireless carrier’s standard rates apply to these messages. You represent that you are the owner or authorized user of the wireless device on which messages will be received, and that you are authorized to approve the applicable charges.

COOKIES, GRAPHIC INTERCHANGE FORMAT (“GIF”) FILES AND LOCATION BASED FEATURES

Some portions of our website may use a cookie or similar technology to identify users who have previously visited so the user is recognized upon return, thereby saving them time while on our website. A cookie is a small amount of data (often including a unique identifier), that is sent to your browser from a website’s computer(s) and stored on your computer’s hard drive. Some of our cookies may be local shared objects, also known as Flash cookies. Smart Circle uses cookies to understand website usage and to improve the content and offerings on our website. We may use cookies to control the display of advertisements, track usage patterns on the sites, deliver editorial content and personalize information. Our cookies may contain personal information and such cookies may be shared with others to the same extent indicated above. Smart Circle (or service providers on our behalf) may also use cookies to collect aggregate information about users of the website on an anonymous basis. We may share aggregate demographic and usage information with our prospective and actual business partners, advertisers and other third parties for any business purpose. Some of our advertisers may serve you cookies as well. We do not have control over cookies placed by advertisers.

In addition, Smart Circle and our advertising companies may use web beacons to help manage our online advertising. These web beacons enable Smart Circle and our third-party advertising companies to recognize a browser’s cookie when a browser visits this website and to learn which banner advertisements bring users to our website and to send you advertisements that you may find of interest elsewhere on the Internet. Smart Circle and these advertising companies may use information about your visits to this website and other websites on the Internet to provide advertisements about goods and services of interest to you.

This website may use pixels, or transparent GIF files, to help manage online advertising. These files enable us to recognize a unique file on your web browser, which in turn enables us to learn which advertisements bring users to our website. A transparent GIF may enable us to relate your viewing or receipt of a webpage or message to other information about you, including your personal information.

LOG FILES AND AGGREGATE INFORMATION

We may track the total number of visitors to our website, the number of visitors to each page of our website, IP addresses, and the domain names of our users’ Internet service providers, and we may analyze this data for trends and statistics in the aggregate, but such information will be in aggregate form only and it will not contain personal information. Such aggregate information is not linked to any personal information that can identify any individual person.

We may use such aggregate information to analyze trends, administer the website, track users’ movement, and gather broad demographic information for aggregate use. We may share this aggregate information with our Service Providers to assist us in operating the website and to enable them to better understand Smart Circle’s business. We do not respond to Do Not Track Requests.

INFORMATION THIS PRIVACY POLICY DOES NOT APPLY TO

This Privacy Policy does not apply to the collection and use of information by companies that Smart Circle does not control, nor by individuals not employed by Smart Circle and only applies to this website. Any information you provide when you visit websites other than those covered by this Privacy Policy (including Smart Circle affiliated websites) or when you purchase any products or services that may be linked to or advertised on our website by companies and entities other than Smart Circle, is subject to the privacy policies posted on those websites.

LINKS TO THIRD PARTY WEBSITES

Some portions of our website may contain links to other websites on the Internet that are not under the control of or maintained by Smart Circle. Such links do not constitute an endorsement by Smart Circle of those other websites, the content displayed therein, or the persons or entities associated therewith. You acknowledge that Smart Circle is providing these links to you only as a convenience, and you agree that Smart Circle is not responsible for the content of such websites. Your use of these other linked websites is subject to the respective terms of use and privacy policies located on the linked websites.

SOCIAL MEDIA SHARING FEATURES

This website may offer social media sharing features or other integrated tools, which let you share actions you take on this website with other media, and vice versa. These features may collect information about your IP address and which page you are visiting on our website, and they may set a cookie or employ other tracking technologies. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the third party that provides the social sharing feature. Social media sharing features and widgets are either hosted by a third party or hosted directly on our website. Your interactions with those features are governed by the privacy policies of the companies that provide them. For more information about the purpose and scope of data collection and processing in connection with social media sharing features, please visit the privacy policies of the third parties that provide these features.

RIGHTS OF CALIFORNIA RESIDENTS

Beginning January 1, 2020, California residents may exercise certain privacy rights pursuant to the California Consumer Privacy Act of 2018 (“CCPA”). We describe below your rights if you are a California resident.

Right To Know About Personal Information Collected, Disclosed, or Sold

We generally describe in this privacy policy how we collect, use, and share your personal information. In addition to what is described above, as a California resident, you also have the right to request more information regarding the following topics for the preceding 12 months, to the extent applicable:

  • The categories and specific pieces of personal information we have collected about you.
  • The categories of sources from which we have collected your personal information.
  • The business or commercial purpose why we collected or, if applicable, sold your personal information.
  • The categories of third parties with whom we shared your personal information.
  • The categories of personal information that we have shared with third parties about you for a business purpose.
  • If applicable, the categories of personal information that we sold about you and the categories of third parties who received your personal information in the sale.

You may submit a request for the information above by calling us at 888-636-2090 or filling out the web form here. Once you contact us through one of these channels, we will need to confirm your identity to process your request.

Right To Request Deletion Of Your Personal Information

You have the right to request that we delete the personal information we collected or maintained about you. Once we receive your request, we will let you know what, if any, personal information we can delete from our records, and we will direct any service providers with whom we shared your personal information to also delete your personal information from their records.

There may be circumstances where we cannot delete your personal information or direct service providers to delete your personal information from their records. Some of these instances include, but are not limited to, if we need to:

  • retain your personal information to complete a transaction or provide a good or service;
  • detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity;
  • debug to identify and repair errors that impair existing intended functionality;
  • exercise free speech or ensure the right of another consumer to exercise his or her right to free speech;
  • comply with the law; and
  • use your personal information for internal and lawful purposes.

You may submit a request to delete your personal information by calling us at 888-636-2090or filling out the web form here. Once you contact us through one of these channels, we will need to confirm your identity to process your request.

Right to Opt-Out of the Sale of Personal Information

We do not and will not sell your personal information to third parties. As such, there is no need to submit a request for us to not sell your personal information. If you have any questions, feel free to contact us at 888-636-2090.

Right to Non-Discrimination for the Exercise of Your Privacy Rights

We will not discriminate against you for exercising any of your rights under the CCPA, as described above. This includes, but is not limited to:

  • denying good or services to you;
  • charging you different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  • providing a different level or quality of goods or services; or
  • suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Authorized Agent

You may use an authorized agent to submit requests on your behalf to exercise the rights above.

CONTACTING US

If you have any questions regarding this Privacy Policy, you may contact us at 888-636-2090.