GDPR

The GDPR (General Data Protection Regulation) is an important piece of legislation that is designed to strengthen and unify data protection laws for all individuals within the European Union. The regulation became effective and enforceable on the 25th May 2018.

Our commitment: Circulate Capital is fully committed to compliance with the GDPR.

Who are we?

We are Circulate Capital, an investment management firm dedicated to financing companies, projects and infrastructure that prevent the flow of plastic waste into the ocean.

Circulate Capital, LLC , is a Delaware limited liability company and our registered address is c/o RPCK Rastegar Panchal, 10 East 40th Street, Suite 3307, New York, NY 10016.

Definitions

“Non Personal Information” is information that is not personally identifiable to you and that we automatically collect when you access our Website with a web browser. It may also include publicly available information that is shared between you and others.

“Personally Identifiable Information” is non-public information that is personally identifiable to you and obtained in order for us to provide you within our Website. Personally Identifiable Information may include information such as your name, email address, and other related information that you provide to us or that we obtain about you.

How do we collect information from you?

We obtain information about you when you use our website, for example, when you contact us about products and services.

Use of ‘cookies’

Our Website uses “Cookies” to identify the areas of our Website that you have visited. A Cookie is a small piece of data stored on your computer or mobile device by your web browser.

We use Cookies to personalize the Content that you see on our Website. Most web browsers can be set to disable the use of Cookies. However, if you disable Cookies, you may not be able to access functionality on our Website correctly or at all.

We never place Personally Identifiable Information in Cookies.

How is your information used?

We may use your information to:

carry out our obligations arising from any contracts entered into by you and us;
dealing with entries into a competition;
seek your views or comments on the services we provide;
ask you to provide a testimonial for the services we provide;
notify you of changes to our services;
send you communications which you have requested and that may be of interest to you.
These may include information and updates on Circulate Capital or promotions of our associated companies’ goods and services.

We review our retention periods for personal information on a regular basis. We are legally required to hold some types of information to fulfil our statutory obligations. We will hold your personal information on our systems for as long as is necessary for the relevant activity, or as long as is set out in any relevant contract you hold with us.

Security precautions in place to protect the loss, misuse or alteration of your information

When you are on a secure page, a lock icon will appear on the bottom of web browsers such as Microsoft Internet Explorer.

Non-sensitive details (your email address etc.) are transmitted normally over the Internet, and this can never be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. Once we receive your information, we make our best effort to ensure its security on our systems. Where we have given (or where you have chosen) a password which enables you to access certain parts of our website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Who has access to your information?

We will not sell or rent your information to third parties.

We will not share your information with third parties for marketing purposes.

Third Party Service Providers working on our behalf: We may pass your information to our third party service providers, agents subcontractors and other associated organisations for the purposes of completing tasks and providing services to you on our behalf (for example to send you mailings). However, when we use third party service providers, we disclose only the personal information that is necessary to deliver the service and we have a contract in place that requires them to keep your information secure and not to use it for their own direct marketing purposes. Please be reassured that we will not release your information to third parties beyond Achieve Unlimited for them to use for their own direct marketing purposes, unless you have requested us to do so, or we are required to do so by law, for example, by a court order or for the purposes of prevention of fraud or other crime.

We may transfer your personal information to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, or if we’re under a duty to disclose or share your personal data in order to comply with any legal obligation or to enforce or apply our terms of use or to protect the rights, property or safety of our supporters and customers. However, we will take steps with the aim of ensuring that your privacy rights continue to be protected.

Third party tracking tools

We also use third party tracking tools to improve the performance and features of our Website. These third party tracking tools are designed to collect only Non-Personal Information about your use of our Website. However, you understand that such tools are created and managed by parties outside our control. As such, we are not responsible for what information is actually captured by such third parties or how such third parties use and protect that information.

You can opt-out of Google Analytics for Display Advertising and by visiting the Google Ads Settings page. Google also recommends installing the Google Analytics Opt-out Browser Add-on for your browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

Links to other websites

Our website may contain links to other websites run by other organisations. This privacy policy applies only to our website‚ so we encourage you to read the privacy statements on the other websites you visit. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our website.

In addition, if you linked to our website from a third party site, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party site and recommend that you check the policy of that third party site.

Your choices

You have a choice about whether or not you wish to receive information from us. If you do not want to receive direct marketing communications from us about our products and services or you prefer that we not hold certain types of information, then you can select your choices by ticking the relevant boxes situated on the form on which we collect your information.

We will not contact you for marketing purposes by email, phone or text message unless you have given your prior consent. You can change your contact preferences at any time by contacting us by email: hello@circulatecapital.com.

16 and under

We are concerned to protect the privacy of children aged 16 or under. If you are aged 16 or under‚ please get your parent/guardian’s permission beforehand whenever you provide us with personal information.

How you can access and update your information

The accuracy of your information is important to us. We’re working on ways to make it easier for you to review and correct the information that we hold about you. In the meantime, if you change email address, or any of the other information we hold is inaccurate or out of date, please email us at hello@circulatecapital.com.

You have the right to ask for a copy of the information Circulate Capital holds about you. Please email us to ask for a review at any time.

Automatic information

We automatically receive information from your web browser or mobile device. This information includes the name of the website from which you entered our Website, if any, as well as the name of the website to which you’re headed when you leave our website. This information also includes the IP address of your computer/proxy server that you use to access the Internet, your Internet Website provider name, web browser type, type of mobile device, and computer operating system.

We use all of this information to analyse trends among our Users to help improve our Website.

Transferring your information outside of Europe

As part of the services offered to you through this website, the information which you provide to us may be transferred to countries outside the European Union (“EU”). By way of example, this may happen if any of our servers are from time to time located in a country outside of the EU. These countries may not have similar data protection laws to the UK. By submitting your personal data, you’re agreeing to this transfer, storing or processing. If we transfer your information outside of the EU in this way, we will take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected as outlined in this Policy.

If you use our services while you are outside the EU, your information may be transferred outside the EU in order to provide you with those services.

Review of this policy

We keep this Policy under regular review. This Policy was last updated in October 2019.