Circle Pass service (provided by Startup Commons) collect information from you when you create a Circle Pass Global User Account or setup a connected Service Provider Service (a “SP Service”), when you create (or any other user creates) a Circle Pass user account in order to manage your account or to utilize as a Circle Pass user (a “User”) any Service Provider Services (a “SP Service”), when any user without a User Account accesses information on Circle Pass website or any SP Service. User may be asked to enter your: name, e-mail address, mailing address, phone number, social network identity/connection or other similar information.
What do we use your information for?
Any of the information we collect from you may be used in one of the following ways:
To personalize your experience (your information helps us to better respond to your individual needs);
To make sure we are keeping the records required by law in EU, most importantly GDPR.
To match SP Services and facilitate communication between you and the SP services you connect to your account.
Research and analyse market trends;
Help find and develop more products and services for our users and to our connected Service Providers
Respond to and investigate violations of this Privacy Policy or other misconduct; and
Protect the interests of the Circle Pass platform, our users (as permitted and/or required by law) and Startup Commons.
Your information, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent.
The email address you provide may be used to send you information and updates pertaining to your Circle Pass User Account or SP Services you have connected, in addition to receiving occasional service updates, related product or service information, etc.
Note: If at any time you would like to unsubscribe from receiving future emails that do not pertain to, as applicable, the SP Services you connected with or your User Account, you can adjust your settings directly via such emails "unsubscribe" link when received.
How do we protect your information?
We implement a variety of security measures to maintain the safety of your personal information when you create a User Account or Connected Serviceand any time you enter, submit, or access your personal information.
We offer the use of a secure server and data storing options. All supplied sensitive information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our, your own, blockchain or connected Service Providers databases only to be accessible by those you have authorized with special access rights to your information.
Upon establishing a User Account or SP Service Connection, and from time to time going forward (in accordance with any applicable laws), your private information (account information, financials, etc.) will be kept securely on your account file in order to facilitate your future communication with the Startup Commons.
Do we use cookies?
Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser (if you allow) that enables the sites or service providers systems to recognize your browser and capture and remember certain information.
In our effort to offer better service experiences, more data for you and better tools in the future, we use cookies to help us compile aggregate data about traffic and interaction on your activities with our service and connected SP Services, understand and save preferences of Users for future visits. All data collected is available to you and use of this data is under your control.
Third Party Links
Startup Commons, Service Providers, Users or other third parties may provide links to other websites. Because Startup Commons has no control over these websites and can not always manage the provision of links to such websites, Startup Commons does not acknowledge or endorse the availability, existence or practice of any privacy policies on these external domains. We strongly encourage you to review the privacy policy of these external websites before providing or sharing access to your personal information.
Do we disclose any information to outside parties?
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information without your specific permission. We work with Service Providers who assist us in operating our website, conducting our business, or servicing you. We release your information only by your permission or potentially when we believe release is required to comply with the law, enforce our site policies, or protect our or others legal rights or safety. However, non-personally identifiable statistical information may be provided to other parties in marketing, advertising, or other uses.
General Data Protection Regulation (GDPR) Compliance
Because we value your privacy, want to be part of My Data movement and believe the future of online services is more user centric, we have taken the necessary precautions to be in compliance with the EU General Data Protection Regulation. We therefore will not use or distribute your personal information to outside parties without your consent.
As part of the General Data Protection Regulation, all users of our site may make any changes to their information and data sharing settings at anytime via Circle Pass Account.
Online Privacy Policy Only
This online privacy policy applies only to information collected through our website, connected SP Services or any other information linked to your Circle Pass Account.
Your Consent
By using our site, you consent to this Privacy Policy.
Changes to our Privacy Policy
If we decide to change our privacy policy, we will post those changes on this page, send an email notifying you of any changes, send or show notifications via UI and/or update the Privacy Policy modification date below.
Edit your profile or amend your personal information
You have the right to view or edit your personal information when you are signed into your Circle Pass User Account.
If you are the administrator of connected SP Service, you have the right to view or edit information of your connected service when you are signed into Circle Pass as the Service Provider administrator. You have full control to limit any personal information from being displayed on your User Account for the public to view. You may limit the information yourself when you are signed into your User Account.
Contacting Us
If there are any questions regarding this privacy policy you may contact us via our Support Portal.
