Privacy Policy
This Privacy Policy needs to be read in conjunction with our Terms of Service and you acknowledge and agree you have read and agreed to both if you use our Website and our Services.
This Privacy policy (“Policy”) describes how and when Circular Parts ApS (“Circular Parts ApS”, Circularparts.com, “we”, “us”) collects, stores, uses, and shares your information when you use our Services.
When using any of our Services you consent to the collection, transfer, manipulation, storage, disclosure, and other uses of your information as described in this Privacy Policy.
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Introduction
- We are committed to safeguarding the privacy of our website visitors and service users. A visitor of our website or end user of our service is referred to as “you”, “your(s)” or “yourself”.
- This policy applies where we are acting as a data controller with respect to the Personally Identifiable Information (hereinafter to be referred to as “PII”), as defined in Article 4 of the GDPR, of our website visitors and service users; in other words, where we determine the purposes and means of the processing of that personal data.
- Our website incorporates privacy controls which affect how we will process your data. By using the privacy controls, you can specify whether you would like to receive direct marketing communications
- In addition, the terms “collect”, “process”, “treat”, “use”, “share”, “disclose”, “divulge” and analogous words shall refer to your PII and other data collected from our visitors and end users.
- From time to time, this Policy may be translated into other languages for your convenience. The English language version of each of these documents shall be the version that prevails and governs your use of the Site and our products and services. In the case of any conflict between the English language version and any translated version, the English language version will prevail.
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Information We Collect
- When using our Services, we may ask you to provide us with some PII that can be used to contact or identify you, and information on your use or potential use of the Services. PII that we might collect includes information like your email address and name. PII may also include other information you supply to us concerning your preferences and interests expressed in the course of using the Services. By providing us with this information, you consent to your information being collected, used, disclosed, and stored by us in accordance with this Privacy Policy.
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We use your PII to administer your account and provide you services,
to send communications and administrative emails,
to respond to your inquiries, and to send marketing and product update messages to those who ask for such messages.
Overall, through the provision of its Services, we will collect the following types of PII:
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Personal InformationPersonal Information includes information that can be used to personally identify a person or company, including but not limited to first name, last name, title, billing address, email address and telephone numbers.As a company registering for our service, you will be required to submit your Company name, Company Address, registration number, email, telephone number etc.
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Personal Information Collected via Third-Party ToolsPersonal Information Collected via Third-Party Tools includes such information as aggregated user statistics, analytics, demographic information, and website usage information. As our user, you will generally be able to control and select the amount and type of PII you may disclose to us.
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Technical Information Collected via our websiteAs you navigate through the website, certain information can be passively collected (that is, gathered without you actively providing the information) using various technologies and means, such as Internet Protocol addresses, cookies, Internet tags, and navigational data collection.
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Internet Protocol (IP) addressesAn IP Address is a number assigned to your computer by your Internet service provider so you can access the Internet and is generally considered to be non-personally identifiable information, because in most cases an IP address is dynamic (changing each time you connect to the Internet), rather than static (unique to a particular user's computer). We use your IP address to diagnose problems with our server, report aggregate information, determine the fastest route for your computer to use in connecting to our website, and administer and improve services to our consumers.
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CookiesA “cookie” is a bit of information that a website sends to your web browser that helps the site remember information about you and your preferences. “Session cookies” are temporary bits of information that are erased once you exit your web browser window or otherwise turn your computer off. Session cookies are used to improve navigation on websites and to collect aggregate statistical information.
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Persistent CookiesPersistent cookies are more permanent bits of information that are placed on the hard drive of your computer and stay there unless you delete the cookie. Persistent cookies store information on your computer for a number of purposes, such as retrieving certain information you have previously provided (e.g., username), helping to determine which areas of the website visitors find most valuable and customizing the website based on your preferences.
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Internet tagsInternet tags, also known as single-pixel GIFs, clear GIFs, invisible GIFs, and 1-by-1 GIFs, are smaller than cookies and tell the Site's server information such as the IP address and browser type related to the visitor's computer.
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Navigational dataNavigational data is also known as “log files,” “server logs”, “clickstream” data and “Internet Tags”, and is used for system management, to improve the content of the site, for market research purposes, and to communicate information to visitors.
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- We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
- You can instruct your device or browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie. If you do not accept cookies, however, you may not be able to use all functionality of our Services.
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Third-party links and services
- It is possible that the Website will contain links to third-party websites and services. Please remember that when you use a link to go from our website to another website or you request a service from a third party, this privacy policy no longer applies.
- Your browsing and interaction on any other website, or your dealings with any other third-party service provider, is subject to that website’s or third-party service provider’s own rules and policies.
- We do not monitor, control, or endorse the privacy practices of any third parties.
- We encourage you to become familiar with the privacy practices of every website you visit or third-party service provider that you deal with and to contact them if you have any questions about their respective privacy policies and practices.
- This privacy policy applies solely to personal information collected by us through our website and functionality and does not apply to these third-party websites and third-party service providers.
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Use and Disclosure of Personal Information
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We do not use or disclose your PII without your consent unless one of the following circumstances applies:
- We will need to use your PII in order to fulfil our obligations to you.
- We may share aggregated information with third parties that do not include PII and we may otherwise disclose aggregated service usage information with third parties.
- We will use the information you provide to bill and collect sums owed to us. Uses for this purpose include sending you emails, receipts, and notices of delinquency, to alert you if we need a different credit/debit card number, and to otherwise try to collect money owed. Financial transactions relating to our website and services are handled by our payment services provider called ReePay. We advise you to read and agree to their terms and conditions and their privacy policy as well when using our website. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds.
- We may send you informational and promotional content in accordance with your marketing preferences. You can stop receiving our promotional emails by following the unsubscribe instructions included in every email.
- We may use your information to request feedback and to contact you about your use of our website, promotion, survey or other site feature.
- We may use your information as part of our efforts to keep our website safe and secure (for example, for fraud monitoring and prevention).
- We may use your information and PII as supporting items in order to enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract, as well as to respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond. We may send you system alert messages. For example, we may inform you of temporary or permanent changes to our Services, such as planned outages, new features, version updates, releases, abuse warnings, and changes to our Privacy policy.
- We may share Personal information with third parties if access, use, or disclosure of such information is necessary to (a) satisfy applicable law, regulation, legal process or an enforceable governmental request, (b) enforce the applicable Terms of service, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address fraud, security or technical issues, or (d) protect against harm to the rights, property or safety of Circular Parts ApS, its users or the public as required or permitted by law.
- If our business is sold or merges in whole or in part with another business that would become responsible for providing the website to you, we retain the right to transfer your PII to the new business. The new business would retain the right to use your PII according to the terms of this Privacy Policy as well as to any changes to this privacy notice as instituted by the new business. We will also retain the right to transfer your PII if our company files for bankruptcy and some or all of our assets are sold to another individual or business.
- We may disclose your information to our third-party Help Center service provider Help Scout. They provide assistance and information when users reach out to us through our Help Center.
- Finally, we may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
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We do not use or disclose your PII without your consent unless one of the following circumstances applies:
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Retaining and Deleting Personal Data
- Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
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We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements.
We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation with respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements. If you would at any point wish for us to modify or delete any data we hold about you, kindly contact us at info@circularparts.com or call +45 9740 5000.
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Your Privacy Rights as Data Subject
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As we mentioned hereabove, for the purposes of the General Data Protection Regulation or GDPR, for European Union residents,
Circular Parts ApS is a “data controller” of the PII you provide to us for the primary purposes of providing you with our services.
This section below covers the certain situations that you, as a data subject, and we as a data controller, are most likely to see, but you should also carefully review the full list of data subject rights here: https://gdpr-info.eu/chapter-3/ and https://gdpr-info.eu/chapter-4/
- You have the right to be informed about the PII we collect from you, and how we process it. For our European Union customers and users, by signing up, you agree to the terms and conditions of our services and hereby acknowledge, agree and unequivocally consent to the collection, processing, management, treatment, transfer and authorization of your PII by Circular Parts ApS, its affiliates and authorized third parties.
- If you are resident of Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html
- You can request information provided are “forgotten”; that is, to have your entire PII removed from our service. If we are asked to do this, in accordance with Article 17 GDPR, we will remove any PII we collected from you as requested. We will also need to contact any third parties that process your PII on our behalf, such as our cloud service providers. To ensure that any personal data in the possession of Circular Parts ApS can be removed in a timely manner, you can relay any request to be “forgotten” to us by submitting a request.
- As a data subject, in accordance with Article 15 GDPR, you have the right to obtain confirmation as to whether or not we process your personal data and, where we do, access the personal data. You can always ask us to confirm how and where your PII is being stored and processed. You also have the right to know how that data is shared with third parties by us.
- As a data subject, in accordance with Article 16 GDPR, you have the right to have any inaccurate PII about you rectified and, taking into account the purposes of the processing, to have any incomplete PII data about you completed.
- In some circumstances, you have the right to the erasure of your data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; y ou withdraw consent for consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and/or the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include situations where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation or the establishment, exercise or defence of legal claims.
- In some circumstances, you have the right to restrict the processing of your data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the data for the purposes of our processing, but you require data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or reasons of important public interest.
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In accordance with Article 18 GDPR, you have the right to object to our processing of your data on grounds relating to your particular situation,
but only to the extent that the legal basis for the processing is that the processing is necessary for:
- the performance of a task carried out in the public interest or the exercise of any official authority vested in us;
- direct marketing (including profiling);
- processing for purposes of scientific/historical research and statistics;
- in relation to automated decision-making and profiling;
- or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
- In accordance with Article 20 GDPR, our users located in the EU may request Circular Parts ApS to send them any PII in our possession. In this case, we will provide you with any PII that you have in a commonly used, machine-readable format.
- To the extent that the legal basis for our processing of your personal information is consent, in accordance with Article 7 (3) GDPR, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
- You have the right to file a complaint with supervisory authorities if your information has not been processed in compliance with the GDPR. In accordance with Article 77 GDPR, if the supervisory authorities fail to address your complaint properly, you may have the right to a judicial remedy.
- In respect to data transfers from controllers to processors and/or processors to processors, standard contractual clauses pursuant to Article 28(7) of Regulation (EU) 2016/679 (including enforceable data subject rights and effective legal remedies, pursuant to Article 46(1) and Article 46(2)(c) of Regulation (EU) 2016/679), we act as a data exporter/controller transferring any data provided to us to the data importer/processor. We may transfer the information you provide to us to contractors and affiliated organisations that may be located outside of your home country. By agreeing to use our service and website, you hereby agree to such transfer. It is our responsibility to ensure such third parties agree to the same level of confidentiality as we have with you. As a data exporter, we will make all reasonable efforts to determine that the data importer is able, through the implementation of appropriate technical and organisational measures provide the required service and protect any data provided to them. We will also ensure the data provided to the data importer are used only for specific reasons to which you have consented or as may be required to provide our services to you.
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You may exercise any of your rights in relation to your PII data by means of a written notice to us.
Your privacy notice request must include, at the least, the following information: (i) your complete name, address and/or e-mail address in order for us to notify you of the response to your request;
(ii) attached documents establishing your identity; and (iii) a clear and concise description of the PII with regard to which you seek to enforce any of your privacy rights.
If you request rectification, please indicate amendments to be made and attach documentation to back up your request.
- Upon receipt of your written privacy notice request, and after due review, we may then edit, deactivate and/or delete your PII from our services within thirty (30) days. In case of secure databases under our control where deletion is impossible, we will make such information permanently inaccessible.
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As we mentioned hereabove, for the purposes of the General Data Protection Regulation or GDPR, for European Union residents,
Circular Parts ApS is a “data controller” of the PII you provide to us for the primary purposes of providing you with our services.
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Safeguarding Your Information
- We are committed to keeping the personal information you provide to us secure, and we will take reasonable precautions to protect your data from loss, misuse and unauthorized access, disclosure, alteration, and destruction, taking into account the risks involved in the processing and the nature of the personal data.
- You can be assured that personal information collected through the website is secure and is maintained in a manner consistent with current industry standards, but please remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.
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We have implemented information security policies, rules and technical measures to protect the personal information that we have under our control from:
- unauthorized access;
- improper use or disclosure;
- unauthorized modification;
- unlawful destruction or accidental loss.
- All our employees and data processors (i.e., those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are obliged to respect the confidentiality of the personal information of all users of the Site.
- The importance of security for all PII associated with our users is of utmost concern to us. Your personal information is protected in several ways. We protect the information you input by undertaking reasonable technical and administrative security measures (e.g., firewalls, data encryption, physical & administrative access controls to the data and servers) that limit the risk of loss, abuse, unauthorized access, disclosure, and alteration.
- If you make a payment to us, we use a third-party payment processor, Reepay. Payments are encrypted through the Payment Card Industry Data Security Standard (PCI-DSS) or analogous systems. Your purchase transaction data is stored only as long as it is necessary to complete your purchase transaction. All direct payment gateways adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of credit/debit card information by our site and related courses and its service providers.
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Google Analytics
Our website uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). The information generated by the cookies about your use of our website (including your IP address) will be transmitted to and stored by Google on their servers. Google will use this information for evaluating your use of our website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. Further information about Google’s privacy policy may be obtained from https://www.google.com/privacy.html . You may opt out of Google Analytics by visiting the Google Analytics Opt-out Page.
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Amendments to this Privacy Policy
- Periodically, and at our sole discretion, we may update, change, suspend and/modify our website, our Services, this Privacy Policy and/or our Terms of Use, in whole or in part.
- You should check this page occasionally to ensure you are happy with any changes to this policy. Your use after any changes indicates your acceptance thereof.
- We may notify you of changes to this policy by email.
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Breach of “Privacy”
Users have a right to pursue legally enforceable rights against us if we fail to adhere to the privacy laws. Privacy laws under this agreement shall include reasonable privacy laws acceptable and used in commercial businesses. These laws require not only those users to have enforceable rights against us, but also that users have recourse to courts or government agencies to investigate and/or prosecute non-compliance by Circular Parts ApS.
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Opt out
We offer you choices when we ask for personal information, whenever reasonably possible. Circular Parts ApS provides you the opportunity to ‘opt-out’ of having your personally identifiable information used for certain purposes. You may decline to provide personal information to us and/or refuse cookies in your browser, although some of our features or services may not function properly as a result. If you no longer wish to receive our newsletter and promotional communications, you may opt-out of this by contacting us on the contact information provided on our website or email info@circularparts.com or call +45 9740 5000. By providing information to Circular Parts ApS, you are consenting to the collection, use and disclosure of such personal information in the manner described in this privacy policy.
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Questions and Complaints
If you have any questions or concerns about this Privacy policy, please feel free to contact us at info@circularparts.com or Halkjærvej 18A 9200 Aalborg SV Denmark.
Date of the last effective update is February 28, 2023.