Privacy policy
Naviza B.V. / Circlo / Circlo Loop Privacy Policy
Last updated: 26.09.2024
This Privacy Policy describes how Naviza B.V. through our services Circlo and Circlo Loop ("Circlo", “we”, “us” and “our”) collects, uses, and discloses your personal information when you visit, use our services, or make a purchase from our online store (the "Site") or otherwise communicate with us (collectively the "Services"). This policy reflects our commitment to handling your data responsibly.
Please read this Privacy Policy carefully. By using and accessing any of the services, you agree to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use or access any of the Services.
Changes to This Privacy Policy
Circlo may update this Privacy Policy from time to time, including to reflect changes to our practices or for other operational, legal, or regulatory reasons. Circlo will post the revised Privacy Policy on the Site, update the "Last updated" date and take any other steps required by applicable law.
We collect personal information about you from various sources, including the data you provide directly through your interactions with Circlo, Circlo Loop, and other Circlo initiatives. This includes purchase history, resale activity through Circlo Loop, participation in surveys and/or offline events. We may also collect data through our partnerships with other brands or sustainability initiatives. This data is used to provide recommendations, promote garment resale, recycling, and upcycling initiatives.
To provide the Services, we collect and have collected over the past 12 months personal information about you from a variety of sources, as set out below. The information that we collect and use varies depending on how you interact with us.
In addition to the specific uses set out below, we may use information we collect about you to communicate with you, provide the Services, comply with any applicable legal obligations, enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.
What Personal Information We Collect
· User Interactions: We collect data on how you interact with our site and services, including browsing history, wishlist additions, and cart activity. This helps us improve functionality and personalize your experience.
· Transaction Data: Information regarding your purchases, returns, and resale activity is recorded to fulfill our services and for auditing purposes.
· Behavioral Data: We collect behavioral data through cookies and tracking technologies to tailor our recommendations and content.
The types of personal information we obtain about you depends on how you interact with our Site and use our Services. When we use the term "personal information", we are referring to information that identifies, relates to, describes or can be associated with you. The following sections describe the categories and specific types of personal information we collect.
Information We Collect Directly from You
Information that you directly submit to us through our Services may include:
- Basic contact details including your name, address, phone number, email.
- Order information including your name, billing address, shipping address, payment confirmation, email address, phone number.
- Account information including your username, password, security questions.
- Shopping information including the items you view, put in your cart or add to your wishlist.
- Customer support information including the information you choose to include in communications with us, for example, when sending a message through the Services.
Some features of the Services may require you to directly provide us with certain information about yourself. You may elect not to provide this information, but doing so may prevent you from using or accessing these features.
Cookie Management:
We use cookies and other tracking technologies to enhance your experience on our site. These technologies help us provide essential site functions, analyze site usage, and personalize your experience, including displaying tailored ads and content. Upon your first visit, a cookie banner will be presented to allow you to manage your cookie preferences. You can choose to accept all cookies or opt out of non-essential cookies, including those used for marketing and analytics. You can also manage your cookie settings at any time through your browser or by revisiting the banner.
· Essential Cookies: These are required for the functionality of the website, including enabling you to use basic features like product browsing and checkout.
· Analytics and Performance Cookies: We use these to analyze how users interact with our site, helping us improve functionality.
· Marketing and Targeting Cookies: With your consent, these cookies help us display relevant advertisements and offers.
Information We Obtain from Third Parties
Finally, we may obtain information about you from third parties, including from vendors and service providers who may collect information on our behalf, such as:
- Companies who support our Site and Services, such as Shopify.
- Our payment processors, who collect payment information (e.g., bank account, credit or debit card information, billing address) to process your payment in order to fulfill your orders and provide you with products or services you have requested, in order to perform our contract with you.
- When you visit our Site, open or click on emails we send you, or interact with our Services or advertisements, we, or third parties we work with, may automatically collect certain information using online tracking technologies such as pixels, web beacons, software developer kits, third-party libraries, and cookies.
Any information we obtain from third parties will be treated in accordance with this Privacy Policy. We are not responsible or liable for the accuracy of the information provided to us by third parties and are not responsible for any third party's policies or practices. For more information, see the section below, Third Party Websites and Links.
How We Use Your Personal Information
- Providing Products and Services. We use your personal information to provide you with the Services in order to perform our contract with you, including to process your payments, fulfill your orders, to send notifications to you related to you account, purchases, returns, exchanges or other transactions, to create, maintain and otherwise manage your account, to arrange for shipping, facilitate any returns and exchanges and to enable you to post reviews.
- Your data may be used for marketing purposes, including targeted advertising related to Circlo and Circlo Loop's sustainability campaigns, resale offers, or promotions of recycled/upcycled garments and limited-edition collections through Circlo and Circlo Loop. You can manage your preferences for these communications through your account settings or opt out of promotional emails at any time.
- Security and Fraud Prevention. We use your personal information to detect, investigate or take action regarding possible fraudulent, illegal or malicious activity. If you choose to use the Services and register an account, you are responsible for keeping your account credentials safe. We highly recommend that you do not share your username, password, or other access details with anyone else. If you believe your account has been compromised, please contact us immediately.
- Communicating with you. We use your personal information to provide you with customer support and improve our Services. This is in our legitimate interests in order to be responsive to you, to provide effective services to you, and to maintain our business relationship with you.
We may share your personal information with third-party providers, including Meta, Google, Klaviyo, and Google Analytics, for the purposes of marketing, analytics, customer engagement, and facilitating shipping, logistics, and garment recycling services. This includes working with partners who manage Circlo and Circlo Loop resale and recycling processes, including third-party recycling facilities, logistics providers, and technology platforms that support resale and recycling.
In certain circumstances, we may disclose your personal information to third parties for legitimate purposes subject to this Privacy Policy. Such circumstances may include:
- With vendors or other third parties who perform services on our behalf (e.g., IT management, payment processing, data analytics, customer support, cloud storage, fulfilment and shipping).
- With business and marketing partners, including Shopify, to provide services and advertise to you. Our business and marketing partners will use your information in accordance with their own privacy notices.
- When you direct, request us or otherwise consent to our disclosure of certain information to third parties, such as to ship your products or through your use of social media widgets or login integrations, with your consent.
- With our affiliates or otherwise within our corporate group, in our legitimate interests to run a successful business.
- In connection with a business transaction such as a merger or bankruptcy, to comply with any applicable legal obligations (including to respond to subpoenas, search warrants and similar requests), to enforce any applicable terms of service, and to protect or defend the Services, our rights, and the rights of our users or others.
We have, in the past 12 months disclosed the following categories of personal information and sensitive personal information (denoted by *) about users for the purposes set out above in "How we Collect and Use your Personal Information" and "How we Disclose Personal Information":
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Category |
Categories of Recipients |
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We do not use or disclose sensitive personal information for the purposes of inferring characteristics about you.
We have “sold” and “shared” (as those terms are defined in applicable law) personal information over the preceding 12 months for the purpose of engaging in advertising and marketing activities, as follows.
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Category of Personal Information |
Categories of Recipients |
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Identifiers such as basic contact details and certain order and account information |
Business and marketing partners |
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Commercial information such as records of products or services purchased and shopping information |
Business and marketing partners |
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Internet or other similar network activity, such as Usage Data |
Business and marketing partners |
User Generated Content
The Services may enable you to post product reviews and other user-generated content. If you choose to submit user generated content to any public area of the Services, this content will be public and accessible by anyone.
We do not control who will have access to the information that you choose to make available to others and cannot ensure that parties who have access to such information will respect your privacy or keep it secure. We are not responsible for the privacy or security of any information that you make publicly available, or for the accuracy, use or misuse of any information that you disclose or receive from third parties.
Third Party Websites and Links
Our Site may provide links to websites or other online platforms operated by third parties. If you follow links to sites not affiliated or controlled by us, you should review their privacy and security policies and other terms and conditions. We do not guarantee and are not responsible for the privacy or security of such sites, including the accuracy, completeness, or reliability of information found on these sites. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators, except as disclosed on the Services.
Children’s Data
The Services are not intended to be used by children, and we do not knowingly collect any personal information about children. If you are the parent or guardian of a child who has provided us with their personal information, you may contact us using the contact details set out below to request that it be deleted.
As of the Effective Date of this Privacy Policy, we do not have actual knowledge that we “share” or “sell” (as those terms are defined in applicable law) personal information of individuals under 16 years of age.
We retain your data for as long as necessary to manage the full lifecycle of a garment, from purchase to resale through Circlo, Circlo Loop or for other legitimate business purposes. This aligns with GDPR's principles of data minimization and retention. For example, transaction data may be retained for up to 7-10 years for tax compliance, and marketing data for up to 2-5 years after the last interaction. We take appropriate security measures to protect your personal information at every stage.
Please be aware that no security measures are perfect or impenetrable, and we cannot guarantee “perfect security.” In addition, any information you send to us may not be secure while in transit. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us.
How long we retain your personal information depends on different factors, such as whether we need the information to maintain your account, to provide the Services, comply with legal obligations, resolve disputes or enforce other applicable contracts and policies.
You have the right to request deletion of your personal data or ask us to limit how your data is used in conjunction with Circlo and Circlo Loop or recycling programs. Under GDPR, you can request access to your personal data, ask for corrections, or request the deletion of personal data when it is no longer necessary for its original purpose.
Depending on where you live, you may have some or all of the rights listed below in relation to your personal information. However, these rights are not absolute, may apply only in certain circumstances and, in certain cases, we may decline your request as permitted by law.
- Right to Access / Know. You may have a right to request access to personal information that we hold about you, including details relating to the ways in which we use and share your information.
- Right to Delete. You may have a right to request that we delete personal information we maintain about you.
- Right to Correct. You may have a right to request that we correct inaccurate personal information we maintain about you.
- Right of Portability. You may have a right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.
- Right to opt out of Sale or Sharing or Targeted Advertising. You may have a right to direct us not to "sell" or "share" your personal information or to opt out of the processing of your personal information for purposes considered to be "targeted advertising", as defined in applicable privacy laws. Please note that if you visit our Site with the Global Privacy Control opt-out preference signal enabled, depending on where you are, we will automatically treat this as a request to opt-out of the "sale" or "sharing" of information for the device and browser that you use to visit the Site.
- Right to Limit and/or opt out of Use and Disclosure of Sensitive Personal Information. You may have a right to direct us to limit our use and/or disclosure of sensitive personal information to only what is necessary to perform the Services or provide the goods reasonably expected by an average individual.
- Restriction of Processing: You may have the right to ask us to stop or restrict our processing of personal information.
- Withdrawal of Consent: Where we rely on consent to process your personal information, you may have the right to withdraw this consent.
- Appeal: You may have a right to appeal our decision if we decline to process your request. You can do so by replying directly to our denial.
- Managing Communication Preferences: We may send you promotional emails, and you may opt out of receiving these at any time by using the unsubscribe option displayed in our emails to you. If you opt out, we may still send you non-promotional emails, such as those about your account or orders that you have made.
You may exercise any of these rights, where indicated on our Site or by contacting us using the contact details provided below.
We will not discriminate against you for exercising any of these rights. We may need to collect information from you to verify your identity, such as your email address or account information, before providing a substantive response to the request. In accordance with applicable laws, you may designate an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. We will respond to your request in a timely manner as required under applicable law.
We use Shopify's ad services such as Shopify Audiences to help personalize the advertising you see on third party websites. To restrict Shopify merchants that use these ad services from using your personal information for such services, visit https://privacy.shopify.com/en.
Complaints
If you have complaints about how we process your personal information, please contact us using the contact details provided below. If you are not satisfied with our response to your complaint, depending on where you live you may have the right to appeal our decision by contacting us using the contact details set out below, or lodge your complaint with your local data protection authority.
As we operate within the EU, your personal information will be transferred, stored, and processed in compliance with the General Data Protection Regulation (GDPR). We are committed to maintaining GDPR-compliant data protection standards across all relevant jurisdictions within the EU.
Please note that we may transfer, store and process your personal information outside the country you live in, including the United States. Your personal information is also processed by staff and third-party service providers and partners in these countries.
If we transfer your personal information out of Europe, we will rely on recognized transfer mechanisms like the European Commission's Standard Contractual Clauses, or any equivalent contracts issued by the relevant competent authority of the UK, as relevant, unless the data transfer is to a country that has been determined to provide an adequate level of protection.
Breach Notification:
In the event of a data breach that compromises your personal information, we will take immediate steps to investigate and mitigate the issue. We will notify affected users via email or other communication channels within 72 hours of becoming aware of the breach, as required by applicable data protection laws. The notification will include details of the breach, the information affected, and any recommended actions you should take to protect yourself.
Contact
Should you have any questions, about our privacy practices or this Privacy Policy, or if you would like to exercise any of the rights available to you may contact us via email at info@circlo.com.
For the purpose of applicable data protection laws, we are the data controller of your personal information. At this time, we do not have representatives in North America or the UK, as our operations are focused solely on the EU.