Circhoolar Privacy Policy

Scope and Consent

This Privacy Notice describes

  • the personal information we collect and how we use that information
  • when we might disclose your personal information
  • how we keep and protect your personal information

It applies to this Site and to any Services where this Privacy Notice is referenced. By using our Services and/or registering for an account, you are accepting the terms of this Privacy Notice and our Terms of Use. If you do not provide the information we require, we may not be able to provide all of our Services to you. Circhoolar is responsible for the collection, use, disclosure, retention and protection of your personal information under our privacy standards and applicable national laws. Circhoolar may transfer data to Related Companies as described in this Privacy Notice who may process and keep your personal information on servers in the European Union, United States and elsewhere in the world where our data centres are located. Where we disclose your information to third parties that are located overseas, or where your information is held in our overseas servers, we will take reasonable steps to ensure that your personal information is protected in accordance with law.

What is Personal Information?

'Personal information' is information or an opinion about an identified individual, or an individual who is reasonably identifiable, either from the information directly or from that information combined with other information that we have, or are likely to have, access to. Personal information doesn’t include de-identified, anonymous or aggregated information that can no longer be used to identify a specific person.

Public Information?

Public information is any information, including personal information, you share with a public audience, including personal information you publish on our Site. Public information is available to anyone on or off our Services and can be seen or accessed through online search engines, APIs, and offline media, such as on TV.

Changes to this Private Notice

We can change this Privacy Notice at any time by posting the updated terms to the Site. The updated terms automatically take effect 14 days after they are posted. We may announce any changes to this Privacy Notice on our Site and/or via email if we believe they are material.

Collection

We collect information you give us including:

  • When you register for an account Information such as your name, addresses, telephone numbers, email addresses or user ID (where applicable) when you register for an account with us
  • When we verify you or your account we may collect and process information (as permitted by law) to authenticate you or your account, or to verify the information that you provided to us
  • When you transact on or use our Services such as when you post an ad, reply to an ad, communicate with us or other users, information you provide for the Services that you use or during a transaction or other transaction-based content. We may also collect your financial information (such as credit card or bank account numbers) if you buy a feature from us or are required to pay fees to us
  • When you engage with our community such as when you submit a web form or participate in community discussions or chats
  • When you interact with your account such as updating or adding information to your account, adding items to alerts lists and saving searches. Sometimes you may also give us your age, gender, interests and favourites
  • When you contact us such as through a web form, chat or dispute resolution or when we otherwise communicate with each other. We may also record our calls with you (if we have your consent to do so)
  • When you submit your resume such as if you choose to submit your resume to advertisers on our site for consideration

We collect information automatically including:

  • Information from the devices you use when interacting with us or our Services such as device ID or unique user ID, device type, ID for advertising and unique device token
  • Information about your location such as geo-location
    • Google Maps: if you provide your business address when you create a listing, we may display the address on a map (Google Maps), in your respective listings. For this purpose, we transmit the address data to external service providers such as Google Ireland Limited for the use of Google Maps (please refer to Google's Privacy Notice). If a user does not want their location details to be shown on a map in their respective listings, they can contact Circhoolar customer service at the help desk at any time.
  • Computer and connection informations such as statistics on your page views, traffic to and from the sites, referral URL, ad data, your IP address, your browsing history and your web log information
  • We collect information using cookies, web beacons and similar technologies including:

    • Information about the pages you view, the links you click and other actions you take on our Services, or within our advertising or email content. For more information about our use of these technologies and how to control them, see our notice on Cookies, Web Beacons and Similar Technologies
    • Without limiting the general application of the Cookies Web Beacons and Similar Technologies Policy.

Information we collect from other resources including:

Information we get from our Related Companies which we use in order to provide you with value-added services as well as market our Services to you which may be of interest to you, for instance, where we may be able to offer you services that you appear interested in but are not available from our Related Companies. We may also use your personal information that we have collected from our Related Companies in order to manage your account, run internal analytics and develop business strategies across our associated brands

Information we get from third parties:

which we may use to supplement your account information. For example, we may collect and use demographic information that is publicly available, additional contact information, credit check information and information from credit bureaus, as allowed by applicable national laws

Information from social media sites when you use those sites to register, share information or connect to your account. Those sites may automatically give us access to some personal information they hold about you (e.g., content you viewed, content you liked, and information about the advertisements you were shown or clicked on, etc.). If you give us access to any account with video content, we may share your video viewing with, or collect information about your video viewing from, third-party social media sites for at least two years or until you withdraw consent. You control the personal information we have access to through your privacy settings on the social media site and the permissions you give us when you grant us access. When you grant us access to information held by social media sites you agree that we may collect, use and retain it in accordance with this Privacy Notice

Information other users may provide about you. If another user gives us information about you, they must tell you about our collection, use, disclosure and retention policies before giving us the information. They must also get your explicit consent before giving us your information

Use and Retention

We use your personal information to provide, improve and personalise our Services

Your personal information allows us to:

  • Provide you with access to and use of our Services as well as access to your history, internal messages and other features we may provide
  • Offer you site content that includes items and services that you may like
  • Customise, measure and improve our Services and those of our Related Companies
  • Provide other services requested by you as described when we collect the information, including those of our Related Companies if applicable
  • To provide you with location-based services (such as advertising, search results and other personalised content)

We use your personal information to contact you about your account:

We may contact you via Circhoolar My Messages, email, telephone, SMS messages or postal mail:

  • To give you customer support about your account such as to troubleshoot problems, to resolve a dispute, to collect fees or monies owed to us, or to get your opinion through surveys
  • For other reasons such as to enforce our Terms of Use or policies and any other agreement we may have with you

We use your personal information too personalise our advertising and marketing, including to:

  • Personalise, measure and improve our advertising and that of our Related Companies
  • Contact you, either via email, telephone, SMS text messages or postal mail to offer you discounts and special promotions and to let you know about our Services and those of our Related Companies (if you have consented to this contact). Message and data rates may apply
  • Deliver targeted marketing, service updates and promotional offers, including in relation to our Related Companies

We use your personal information for legal compliance reasons, including to:

  • Prevent, detect, mitigate and investigate fraud, security breaches, potentially prohibited or illegal activities
  • Enforce our Privacy Notice, our Terms of Use or other policies

Retention of personal informations:

If your account is active, we will keep your personal information as long as we need it for our operations. We may also keep personal information from closed accounts to comply with national laws, stop fraud, collect fees owed, assist with any investigation, enforce our Terms of Use and take other actions under applicable national laws. If we no longer need your personal information, we securely dispose of it.

Choice

Marketing Communications

If you don’t want to receive marketing communications from us, you can unsubscribe via the link in the email you received. Registered users may also unsubscribe via the communication preferences options in their profiles.

Push Notifications

Upon download of certain Services, you are provided the option to opt into receiving push notifications from Circhoolar on your device and within the application. We send you push notifications from time-to-time to (a) inform you of Service-related messages, (b) communicate messages from others in the Circhoolar community and (c) update you about any events or promotions that we or our Related Companies may be running. If you no longer wish to receive notifications from us, you can, where applicable, change your preferences by logging into your account or by disabling notifications in your device settings. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.

Targeted Advertising

If you want to learn more about targeted advertising (also known as behavioural advertising), and turn on or off individual companies for online behavioural advertising, you can do so on
www.youronlinechoices.com.au.

Access

You can see, review and change your personal information by signing in to your account. Please update your personal information immediately if it changes or is inaccurate. Once you make a public posting, you may not be able to change or remove it. If you ask us to, we will close your account and remove your personal information from view as soon as reasonably possible, based on your account activity and as required under applicable national laws.

We will honour your right to request access to, or modification or deletion of, your personal information. We may have the right to withhold that access or refuse to modify or erase your personal information under applicable national laws, but we will give you reasons if we do so. To contact us about access and to find out if any fees apply, please contact Customer Service or by using the contact details above.

Disclosure

We disclose your information to our Related Companies, who may use it to:

  • provide joint content, services and marketing (like registration, account management, transactions and customer support)
  • help detect and stop possible fraud and illegal acts, violations of our Terms of Use, and data security breaches
  • offer you personalised advertising
  • guide decisions and business strategy about their products, sites, applications, services, tools and marketing communications

We may disclose your information to third-parties:

  • third party service providers who help us provide our Services, payment processing services, assist us in providing customised advertising, help us with the prevention, detection, mitigation and investigation of potentially illegal acts, violations of our Terms of Use, fraud and/or security breaches, bill collection, affiliate and rewards programs and other business operations
  • other third parties when you have given consent to share your information via Circhoolar

We may disclose your information to law enforcement and and other parties in connection with the law, including:

  • law enforcement or governmental agencies, or authorised third-parties, in response to a verified request regarding a criminal investigation, alleged or suspected illegal activity, or any other activity that may expose us, you or any of our users to legal risk
  • participants of the Circhoolar 'Verified Rights Owners Program' under confidentiality agreement, if we decide that it is necessary to disclose that information in connection with an investigation of fraud, intellectual property infringement, piracy or other unlawful activity
  • credit agencies or bureaus as authorised by applicable national laws
  • third parties commencing, or involved in, a legal proceeding if they provide us with a subpoena, court order or similar legal document
  • other third parties to comply with our legal requirements, enforce our Terms of Use, respond to claims that a listing or other content violates the rights of others, or if we otherwise believe in good faith that the disclosure is needed to prevent imminent physical harm, harm to property, financial loss or to report suspected illegal activity

Change of ownership

If we were to merge with or be bought by another company, we may share information with them in accordance with our privacy standards. The new combined entity would comply with this Privacy Notice. If your personal information is to be collected, used, disclosed or retained for any purposes not covered in this Privacy Notice, you will receive advance notice of any changes to the processing of your personal information.

Security

We protect your information using technical and administrative security measures. Our safeguards include firewalls and data encryption, physical access controls to data centres and information access authorisation controls. If you believe your account has been abused, please contact Customer Service.

Important Information

Social login

When you use social login:

  • If you sign into your social network account using the same email that you previously used to register for an account with us, you will access your existing account with us
  • If you sign into your social network account using an email address that we don’t recognise in our systems, a new account will be created in our systems for you

You may use social login or regular sign in each time you login into your account with us. If you use regular sign in but a password has not been issued to you (because you registered through social login) you need to get a password through the password reset flow.

When you use social login the 'keep me signed in' policies of the social network provider apply. We do not control those policies. For your safety we recommend that you:

  • Don’t use social login if you are accessing our Services using a public or shared device
  • Visit your social network provider site to learn about their sign in policies and your options

Unwanted or threatening email We do not tolerate abuse of our Services. You do not have permission to add other users to your mailing list, call or send SMS messages for commercial purposes, even if a user bought something from you, unless the user has given their explicit consent. Sending unwanted or threatening email and SMS messages is against our Terms of Use. To report spam or spoof emails please contact Customer Service.

Third party privacy practices

This Privacy Notice addresses only the use and disclosure of personal information we collect from you. If you disclose your information to others, or if you are directed to a third party website, their privacy notices and practices will apply.

We can’t guarantee the privacy or security of your information once you provide it to a third party. You should check the privacy and security policies of your trading partner before entering into a transaction and choosing to share your information, even when dealing with buyers or sellers on our site.