Security & Privacy



Effective Date: February 28, 2011

This privacy policy applies to the following websites:

• www.circles.com
• www.circlesmembers.com

This privacy policy informs users of the above websites ("members" or "you") how Circle Company Associates, Inc ("Circles" or "we") gathers and uses personal information.

What Information Do We Collect
When corporations (such as an organization you work for or of which you are a customer) (our "Clients") sign up for Circles' services, or when you first contact Circles for services, we will collect basic contact information, such as name, email address, address and phone numbers. Circles collects this contact information so that we can communicate with you regarding your requests for personal services as well as deliver relevant content to you. If you were introduced to Circles as an employee or customer of an organization that is a Circles' client, we may also collect your job title and one or more unique identifiers (for example, your employee code). Beyond this basic contact information, members may also have the option of providing additional information such as home and mobile contact information and credit or debit card number.

Circles may also collect information from you about your personal or professional interests, demographics and your experience with our services and the products and services provided by our third party service providers. Circles may also ask you for your age/date of birth, marital status, and gender in order to tailor its services to suit you or to fulfill a request you place. 

Service Requests
When making a request, members are asked to provide information about the service desired and any additional information needed to complete the member's request.

How Do We Use Personal Information We Collect?
We use personal information collected in order to process the service requests that you make and to communicate about those service requests to our third party service providers who may fulfill your requests. We also use personal information collected to offer services to you that may be of interest to you and to tailor communications that are sent to you.

Subject to any "opt-out" exercised to you as described below, Circles may use your personal information for marketing purposes so that we may provide you with information about products and services which may be of interest to you. Circles may also use your personal information for market research purposes including carrying out member surveys either directly or through a third party survey entity.

In What Circumstances Do We Disclose Personal Information?
Circles does not sell, share or rent individual or personal information of members to any third party, except with your consent or as otherwise described in this privacy policy.

Service Requests
If you place a request for service, Circles will provide your personal information to one or more third pary service providers as reasonably necessary for the service provider to consider or fulfill your request. If the service you request includes air travel we may be required by law or regulation to disclose your personal information (or a portion of it) to the relevant authorities, depending on your travel destination and/or your route. 

Direct Marketing
Subject to your "opt out" as described below, we may use your personal information to send you direct marketing regarding our services. That marketing information may be provided to you by post, email, telephone, SMS or any other form of electronic message or by other methods which may become relevant from time to time. Use of your personal information by any service provider you engage with through our services will be subject to the privacy policies of that service provider, not Circles, and we encourage you to review the privacy policies of any such third party provider before making any disclosure to, or proceeding with any transaction with, any of these third parties. 

Aggregate Information
We may share aggregate information with our clients and potential clients to indicate trends in usage and consumption of our services and for reporting purposes. We may also share aggregate information with our service providers in order to enhance your experience on our site as well as on their sites. This aggregate information is not linked to any personal information that can identify any individual person. 

Other Disclosures
Circles may share your personal information: (a) with our professional advisers and suppliers that provide products and services to help us in running our business; (b) with our affiliated companies (that is, companies under common ownership and control with Circles) in order to fulfill your service request, meet our obligations to our corporate clients, or for processing, storage and handling; (c) with our Clients with regard to frequency of usage of Circles’ services or any complaints we may receive; (d) if you receive our services as a result of being a customer of a Client, for quality control purposes; and (e) with third party survey entities, so that they may provide you with an opportunity to participate in surveys about Circles services.

Circles may also need to disclose personal information when required by law or when we have a good-faith belief that such action is necessary to comply with an appropriate law enforcement investigation, judicial proceeding, court order, or legal process served on our Web site. If all of a portion of Circles or its businesses are acquired by a third party, personal information may be included in the data transferred to the acquirer.

Cookies & Log Files
A cookie is a piece of data stored on the member's hard drive containing information about the member. Except as described below, no personally identifiable information is stored in a cookie on our site. Circles uses cookies to save the member's user name so this information does not have to be re-entered each time the site is visited. If a member or a browser the member uses rejects the cookie, the member will not be limited from using any part of the site.

We use IP addresses to analyze trends, administer the site, track members' movement through the site, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.

Our Partners
Circles partners with a number of third party service providers, who fulfill service requests submitted by members, provide content for our website, and to whose websites we may link. From time to time, certain of our vendors may pay us commission and/or other incentives. Circles is not responsible for the privacy practices of our third party partners or of any linked third party websites, and this privacy statement does not apply to third party websites or to co-branded sites operated by Circles’ business partners. You should review the privacy policies on any third party websites and make whatever investigation you feel necessary or appropriate before making any disclosure to, or proceeding with any transaction with, any of these third parties.

Security
Circles takes commercially reasonable technical and organizational measures designed to protect your personal information against unauthorized disclosure, access, or use. If you have any questions about the security at our web site, you can send an email to privacy@circles.com.

Supplementing Information
In order for this web site to enhance its ability to tailor the site to an individual's preference, we combine information about the purchasing habits of members to create a personalized member profile. When a member makes a purchase from any of our partners, our partners may collect and share that purchase information with us so we can tailor the site to our members' preferences.

Correction/Updating Personal Information
Members can update their personal profile by contacting us through one or more of the methods described in the "How to Contact Us" section below.

Choice/Opt-out
Members have the right to opt-out of receiving direct marketing from us. If you wish to exercise this option, click on the “unsubscribe” link on any e-mail message you receive from us or email us or write to us as described in the "How to Contact Us" section below.

Notification of Changes
If we decide to change our privacy policy, we will post those changes on this page so our members are always aware of what information we collect, how we use it, and under circumstances, if any, we disclose it. If at any point we decide to use personally identifiable information in a manner different from that stated at the time it was collected, we will notify members by way of an email. Members will have a choice as to whether or not we use their information in this different manner.

Jurisdiction
This website, and the services offered by Circles through this website, are for customers located in the United States of America. Although this website may be accessible in other countries, Circles operates this website from its offices in Boston, Massachusetts and subject to the laws of the Commonwealth of Massachusetts and the United States of America. As other places may have laws that may differ from those of Massachusetts and from each other, in order to establish a predictable legal environment, to the extent permitted by law you and Circles hereby agree that this Privacy Policy, and Circles’ privacy practices, will be governed by the substantive laws of the Commonwealth of Massachusetts, without regard to its conflicts of laws principles. If you choose to gain access to this website from locations other than Massachusetts, to the extent permitted by law you hereby consent to the use and disclosure of your information in accordance with this policy and with Massachusetts law.

How To Contact Us
If you have questions or concerns regarding this statement, you may contact us at:

Email: privacy@circles.com

Telephone: (617) 622-6200(617) 622-6200

Postal Mail: Privacy Request, Circles, 300 A Street, Boston, MA 02210