CircleConnect Inc.
9210 Corporate Blvd, Suite 390
Rockville, MD 20850

Last updated on March 28, 2024.

This Privacy Policy is effective immediately for Users who visit or use this Website or its Services after this date.

This document is the privacy policy of our Website, circleconnect.com. Any capitalized terms not defined herein will have the same meaning as defined in our Terms of Service or as otherwise found on our Website.

1. Definitions

1. "Non-Personal Information" (NPI): Information that is generally not personally identifiable. It is obtained automatically when you access our Website with a web browser.
   
2. "Personally Identifiable Information" (PII): Non-public information that is personally identifiable to you and obtained for us to provide you with a product or service. PII may include information such as your name, address, phone number, credit card information, and other related information that you provide to us.
   
   

2. Our Commitment to Your Privacy
This Privacy Policy lets you know what PII we may collect from you, how we may share your PII, and how you can limit our sharing of your PII. We take your privacy seriously, and we will work with you to ensure that you have an enjoyable online experience. With this in mind, Our Company and our affiliates recognize the need for appropriate protection and management of the PII you share with us.

3. Personally Identifiable Information We Collect
Generally, Visitors to our Website control the amount and type of PII you provide to us when using our Website. Visitors to our Website can browse the Website to find out more about us without providing any PII.
However, if you register as a Member or Owner to use the Services on our Website, you must provide PII in order for us to provide you with various features and/or functionality from our Website. As a Member or Owner, we collect your PII in the following ways:

1. Registration
   Upon registration, we receive your name, email address and other information requested.
2. Online Forms
   If online forms are used in our Website, the information you enter into the online forms may include PII.
   
3. Mobile Application
   If we offer a mobile application, and you choose to use it, you may have to provide PII in order to use it.
   
4. Fee and Charges
   Our Website may, either currently or in the future, require payment of fees or charges to use the services or premium features offered on the Website. If you were to make any payments to use the services or premium features, it would necessarily require you to give us payment information (i.e. credit card) for us to bill you
   
   

4. Computer Information We Receive and Record
When you visit our Website we automatically receive and record certain computer information sent by your mobile phone or web browser. The information received is typically considered NPI. We may also collect the following:

1. Cookies
   A Cookie is a small piece of data stored on your computer or mobile device by your web browser that provides anonymous information about how you browse our Website. We use Cookies to identify the areas of our Website that you have visited, to identify you as a Member or Owner so that you can access various places on, or features of, our Website, and to personalize the Content you view on our Website. Your web browser should allow you to disable the use of Cookies, but access to certain pages on, or features of, our Website may be impaired, limited or blocked completely if the ability to accept Cookies is disabled. We don't intentionally place PII in Cookies.
   
2. Clear Gifs ("Web Beacons")
   Clear Gifs, or "Web Beacons", are a technology that allows us to collect general information about your use of our Website and your use of special promotions or newsletters. The information we collect using Web Beacons is compiled to statistically monitor the number of people that open our emails. We use this information to improve our Website and Services. Our Web Beacons are not used to track your activity outside of our Website. We do not intentionally link NPI from Web Beacons to PII without your permission.
   
3. Log Files
   When you visit the Website our servers automatically record certain information sent by your web browser. These server logs may include information such as your web request, IP address, browser type, the webpage you came from, the webpage your going to, URLs, number of clicks, how you interact with links on our Website, domain names, landing pages, pages viewed, mobile carrier, and similar information. We use all of this information to analyze trends among our Users to help improve our Website.
   
4. Google, Inc. ("Google")
   
   1. Google Ad and Content Network Privacy Policy
      Google, as a third party advertisement vendor, uses cookies to serve ads on this Website. The use of DART cookies by Google enables them to serve advertisements to visitors that are based on their visits to this Website as well as other websites on the internet. To opt out of the DART cookies you may visit the Google ad and content network privacy policy at the following url:
      http://www.google.com/privacy_ads.html
      Tracking of users through the DART cookie mechanisms are subject to Google's own privacy policies.
      
   2. Google Analytics Privacy Policy
      This Website uses "Google Analytics", a web analytics service provided by Google. Google Analytics uses Cookies to compile information such as how often users visit our site, what pages they visit, and what other websites they used prior to coming to our Website. The information we receive from Google Analytics is used to improve our Website. Google Analytics collects only the IP address assigned to you on the date you visit our site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit our site, the cookie cannot be used by anyone but Google. Google's ability to use and share information collected by Google Analytics about your visits to our site is restricted by the Google Analytics Terms of Use, found here:
      http://www.google.com/analytics/terms/us.html
      You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser, but it may affect your ability to view and use our Services and Website. To do this, go here: https://tools.google.com/dlpage/gaoptout
      By using this Website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.
      
      

5. How We Use Information
We use information we receive from you in the following ways:

1. To Provide and Improve Our Website
   The PII we receive from you may be used to provide, and make improvements to, our Website.
   
2. To Contact You
   We will use the email address you provided when registering as a Member or Owner to send you information about our Website, to send you Website alerts regarding your use of our Website, and to send you emails with promotional information about our Website or offers from us or our affiliates. You can opt out of receiving this information by changing your contact preferences at any time. While you can opt-out of promotional messages, you cannot opt-out of receiving Website alerts.
   
3. To Share Information with Third Parties
   We do not transfer, sell, assign, rent, or otherwise provide your PII to third parties for marketing purposes. However, we may use your NPI for data aggregation purposes which we reserve the right to sell to other parties. Any such data aggregation would not contain any of your PII. We may provide your PII to affiliates that provide services with regards to our Website. This could include companies that process payments, or webhosting companies, among others. These affiliates will only receive information necessary to provide the respective services and will be bound by confidentiality agreements limiting the use of such information.
   
4. To Offer Service Reviews and Discussion Boards
   Our Website may offer Users the ability to communicate with each other by submitting reviews of products or services, or through online Discussion Boards. We do not filter or monitor what is posted on such discussion boards or otherwise submitted by Users. If you post or submit anything for public viewing you should be cautious of exposing any PII, as information that you submit or post for public viewing is not protected by our Privacy Policy, and we are not liable should you choose to disclose PII through such postings.
   
5. To Comply with Legally Required Disclosure of Information
   In certain instances we may be legally required to disclose your PII. For example, disclosure may be
   1. required by subpoena, law, or other legal process;
   2. necessary to assist law enforcement officials or government enforcement agencies;
   3. necessary to investigate violations of or otherwise enforce our Legal Terms;
   4. necessary to protect us from legal action or claims from third parties including you and/or other Members or Owners; and/or
   5. necessary to protect the legal rights, personal/real property, or personal safety of our company, our Users, employees, and affiliates.
   
   
6. To Disclose Information to Successors
   If our business, whether in whole or in part, is sold to, or merges with, another business that would become responsible for providing the Website to you, we retain the right to transfer your PII to the new owner of the Website. The new owner would retain the right to use your PII according to the terms of this Privacy Policy and to make any changes to this Privacy Policy, in its sole discretion.
   
   

6. Protecting the Privacy Rights of Third Parties
If you submit a review or post information on our Website which contains information about any third party, it is your responsibility to make sure you have permission to submit the information. While we are not legally liable for the actions of our Users, we will remove any postings for which we are notified that such postings violate the privacy rights of others.

7. Opting Out of Sharing Information
You can always opt out of future unaffiliated third-party disclosures of your information. Such opt-out will not affect disclosures otherwise permitted by law including but not limited to disclosures:

1. to our affiliates,
2. to third-parties providing services for our business, such as credit card processing, computer system servicing, shipping, data management, or promotional services,
3. necessary to fulfill your requests,
4. to government agencies, law enforcement officials, or otherwise required to be made under applicable law,
5. previously completed to third parties, or
6. to third parties in connection with contests or promotions you may choose to enter, or third-party offers you choose to accept, after you have opted out.
   
   

8. Changing Personal Information
You may change your PII at any time on our Website. If you need help with updating your PII or removing yourself from our mailing lists, send us an email with your request or contact us using the Contact information found on our Website.

9. Data Retention and Account Termination
In the event that you terminate your registration or other use of the Website or Services we will remove your public posts from view and/or dissociate them from your registration profile, but we may retain information about you for the purposes authorized under this Privacy Policy unless prohibited by law. For example, we may retain information to prevent, investigate, or identify possible wrongdoing in connection with the Service or to comply with legal obligations.

10. Links to Other Websites
On our Website you may find links to other websites. By using our Website you are acknowledging that these websites are not under our control and are not subject to our Privacy Policy. Linked websites may have their own privacy policies. We have no responsibility for linked websites. Links are provided solely for your convenience.
You also acknowledge that your use and access of linked websites is at your own risk. It is your responsibility to check the privacy policies of these websites to see how they treat your personal information.

11. "California Do Not Track" Settings
Some web browsers have settings that enable you to request that our Website does not track your movement within our Website. Our Website does NOT obey such settings when transmitted to and detected by our Website.

1. Changing and Turning off tracking features in your browser. As of the date of last update of this Privacy Policy, visiting the following links will explain how to turn off tracking features and other security settings in your browser:
   
   1. For Internet Explorer visit:
      http://windows.microsoft.com/en-us/internet-explorer/ie-security-privacy-settings#ie=ie-11
      
   2. For Mozilla Firefox visit:
      https://support.mozilla.org/en-US/kb/how-do-i-turn-do-not-track-feature
      
   3. For Google Chrome visit: https://support.google.com/accounts/answer/61416?hl=en
      
   4. For Safari visit: https://support.apple.com/kb/PH11952?locale=en_US
      
2. Google Analytics Opt-out Browser Add-on. Google provides a free add-on to most major browsers that
   you can install to prevent your data from being collected and used by Google Analytics. As of the date of last update of this Privacy Policy, visiting the following link will allow you to download the free Google Opt-out Add-on Tool: https://tools.google.com/dlpage/gaoptout
   
   

12. Protecting the Privacy of Children
We follow the Children's Online Privacy Protection Act (COPPA). Our Website is not intended for use by anyone under 18 years of age (considered to be a "child"). However, we understand that a child may attempt to use the Website. We don't knowingly collect PII from any child. We ask that any parent or guardian who thinks that their child has used or registered for our Website, contact us for removal of information about the child. Please understand that before we remove any information we may request proof of identification. This is to prevent unwarranted or malicious removal of account information. If we discover on our own that a child is accessing our Website, we will delete the information as soon as we discover it, we will not use the information for any purpose, and we will not disclose the information to third parties. Any User of our Website acknowledges that we do not, and have not means by which to, verify the age of Users, nor do we have any liability as a result of our inability to do so. If you are a child you are not allowed to use our Website without first getting the permission of a parent or guardian.

13. Email Policy
We comply with the federal CAN-SPAM Act. This means that we will not sell, assign, transfer, rent, or trade your email address to any unaffiliated third-party without your permission except in the sale or transfer of our business, and you have the choice to opt-out of receiving any further email communication from our Company or affiliates.

14. Security Policy
We have taken steps to build our Website using sophisticated encryption and authentication tools to protect the security of your PII. When we collect your PII through our Website, we will encrypt your PII before it travels over the Internet using industry standards for establishing or conducting secure online transactions. We also use industry standard technologies such as secure routers and fire walls to make sure that your PII is safe. Unfortunately, because of the nature of the Internet, we cannot fully guarantee secure data transmission. After we have received your PII, we have industry standard security measures in place to protect against the loss or misuse of your PII, however, we cannot and do not guarantee against any loss or misuse of your PII. It is your responsibility to protect the password you use for our Website. Do not share your password with anyone. To protect yourself, you need to log out of our Website when are done, whether you are on your own computer or device, on a computer or device shared with someone else, or using a computer or device in a public place or through a public Wi-Fi connection.

15. Changes to Privacy Policy
We always retain the right to modify our Privacy Policy, in whole or in part, so that it complies with changes in laws or to our business practices. We will also change the "Last Updated" date at the beginning of this Privacy Policy. Any changes we make to our Privacy Policy are effective as of this Last Updated date and replace any prior Privacy Policies. We will typically notify users by a message on our Website home page that our Privacy Policy has changed. We may also notify you by email to the address we have for you. We encourage you to review our Privacy Policy periodically to make sure you still agree with it.

16. Questions
Questions about our Privacy Policy may be sent to the contact information found in this document or on the Website.